DOCKET NO: A-98-49

Item: II-B3-127 

2013 – EmplacementInspection Report

EPA INSPECTION No. EPA-WIPP-10.13-22c

OF THE

WASTE ISOLATION PILOT PLANT 

October 22 – 24, 2013

U. S. ENVIRONMENTAL PROTECTION AGENCY 

Office of Radiation and Indoor Air

Center for Waste Management and Regulation

1200 Pennsylvania Avenue, NW 

Washington, DC 20460

January 2014
2

Table of Contents

1.0 Executive Summary........................................................................... 4

2.0 Inspection Purpose and Scope................................................................. 4

3.0 Inspection Team, Observers and Participants............................................. 5

4.0 Performance of the Inspection............................................................. . 6

5.0 Waste Emplacement/WDS............................................................... ... 7

6.0 Magnesium Oxide Backfill................................................................. 12

7.0 Comparison with Inventory limits..........................................................14

8.0 Summary of Results..........................................................................15

Attachments

Attachment A – Inspection Plan.......................................................................16

Attachment B – Summary of Nuclide report through October 24, 2013........................ 17

Attachment C - Materials Emplaced in WIPP as of September 30, 2013.......................18

Attachment D – Procedures Examined................................................................19

Attachment E – Inspection Checklist.................................................................20

Tables

Table A Inspection Participants................................................................. 5

Table B Waste Containers Reviewed During Inspection....................................9

Table C Emplaced CPR Quantities as of .....................................................14

Table D WDS Record of Shielded Container Waste.........................................14

Figures

Figure 1 Typical RH and CH TRU Mixed Waste Disposal Configuration ...............8

Figure 2 Arrangement of disposed waste in a room .........................................9
3

Figure 3 Photo of disposed waste in Panel 6 Room 1........................................ 10

Figure 4 Equipment prepared for RH waste emplacement... ..............................11

Figure 5 Emplaced RH Waste selected for review..............................................11

 

Figure 6 SLB2 in Panel 6 Room 1..............................................................12
4

1.0 Executive Summary

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

October 22 through October 24, 2013, in accordance with 40 CFR 194.21. The WIPP is a disposal

facility for defense-related transuranic (TRU) waste as defined by the WIPP Land Withdrawal Act.

1

EPA first certified that 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 is to determine that waste sent to WIPP during the past year has 

been emplaced in the underground facility in the manner specified in DOE’s Compliance Certification

Application and other approvals. The inspection reviews the site’s ability to receive, process, and

emplace contact-handled and remote-handled TRU wastes within the repository, the emplacement of 

magnesium oxide (MgO) backfill in appropriate amounts to fulfill DOE commitments and 

requirements, and the maintenance of records pertaining to waste shipping, packaging, and 

emplacement, including the electronic Waste Data System (WDS). EPA examined selected activities, 

such as RH and CH waste processing, waste emplacement activities, and record keeping.

EPA concluded that DOE’s emplacement activities are adequate, that cellulosic, plastic and rubber 

material (CPR) is appropriately tracked and recorded, that MgO balances are calculated properly, and 

that MgO is emplaced properly. The Agency observed the use of the proper waste emplacement

procedures in the underground. EPA did not identify any findings or concerns during this inspection.

1WIPP Land Withdrawal Act, Public Law 102-579, Section 2(18), as amended by the 1996 WIPP LWA 

Amendments, Public Law 104-201.

2.0 Inspection Purpose and Scope

The purpose of this annual inspection is to verify that contact-handled (CH) and remote-handled (RH) 

transuranic (TRU) waste sent to WIPP during the past year has been emplaced in the underground 

facility in the manner specified in DOE’s Compliance Certification Application (EPA Air Docket 

A-93-02, Item II-G-01) and other approvals. EPA performed this inspection under the authority of 40 

CFR 194.21, which authorizes the Agency to inspect WIPP during its operational period to verify 

continued compliance with EPA’s WIPP Compliance Criteria and the certification decision of May 18, 

1998. Emplacement of waste and backfill, in particular, is relevant to compliance because the 

emplacement method supports the models that DOE uses in the WIPP performance assessment.

 Activities within the scope of this inspection included: demonstration of the WIPP site’s ability

to receive, process, and emplace remote-handled (RH) and contact-handled (CH) TRU wastes within the 

repository, the use of magnesium oxide (MgO) backfill in amounts to fulfill certification requirements 

and other approvals, maintenance of relevant waste packaging records, including the electronic Waste 

Data System (WDS) and the verification of appropriately implemented quality assurance practices. The 

review and examination of documents related to these activities is an important part of the inspection 

process. The WIPP site is operated by Nuclear Waste Partnership (NWP) under contract to DOE, and the 

majority of waste related activities onsite are described by or controlled through NWP procedures. A list 

of NWP procedures examined during this inspection is provided in Attachment D.
5

3.0 Inspection Team, Observers and Participants

The inspection team consisted of three EPA staff. Trais Kliphaus of the New Mexico Environment 

Department observed the inspection activities. A partial list of inspection participants is provided in 

Table A.

Table A

Inspection Participants

Inspection Team Member Position and Inspection Focus Affiliation

Nick Stone Inspection Leader EPA – Region 6

Jonathan Walsh Inspector EPA - ORIA

Kathleen Economy Inspector EPA - ORIA

Observer Position Affiliation 

Mansour Akbarzadeh Manager Carlsbad Environmental 

Monitoring and Research Center NWP

Terry Batchelder Waste Operations NWP

John Callicoat Delaware Basin Monitoring Lead URS-Professional

Solutions

Randy Britain Manager Waste Operations NWP

Rey Carrasco Manager Geotechnical Engineering NWP

Art Chavez Senior Scientist – EPA Compliance Group NWP

Jennifer Hendrickson Manager - Air Monitoring NWP

Jaci Davis Air Monitoring NWP

Larry Madl Senior Scientist - Scientist – EPA 

Compliance Group

URS-Professional

Solutions

Rick Salness Manager - Environmental and 

Hydrologic Monitoring NWP
6

Tom Klein Scientist – EPA Compliance Group URS-Professional

Solutions

Trais Kliphuis WIPP Group Manager

New Mexico 

Environment 

Department, 

Hazardous Waste 

David Squires Engineering and Technical Services NWP

Kris Kuhlman Sandia PA Team Member - Hydrology SNL

JohnVandeKraats Manager WIPP Mine Operations NWP

Steve Wagner Sandia PA Team Member - FEPs

J Hart & Associates/

SNL

Mike Walentine Waste Data Monitoring NWP

Ty Zimmerly Geotechnical Engineering NWP

NWP - Nuclear Waste Partnership

SNL – Sandia National Laboratories 

4.0 Performance of the Inspection

The inspection took place from October 22 to October 24, 2013, at DOE’s Carlsbad Field Office (CBFO) 

and at the Waste Isolation Pilot Plant (WIPP) facility, which is located approximately 26 miles southeast 

of Carlsbad, New Mexico. The opening meeting with CBFO and NWP personnel was held on the 

morning of October 22, 2013. Facility staff presented information addressing program status, updates 

and changes since the last EPA emplacement inspection which took place from July 17 to July 19, 2012.

The primary focus of the emplacement inspection was to determine the nature and extent of changes that 

had taken place in the areas of emplacement activities and documentation since last year’s inspection.

EPA inspectors accompanied CBFO and NWP personnel into the underground repository on the 

morning of October 23, in order to examine waste packages and MgO that had been emplaced in Panel 

6. Inspectors reviewed records documenting that waste emplacement and MgO tracking were conducted 

in accordance with procedures. Inspectors selected several containers and recorded their numbers (see 

Figure 3), the records for these containers were examined both in the repository and later using the WDS 

computer database, to verify correct waste information is recorded by DOE. NWP personnel answered 

EPA questions about how waste is handled and emplaced. The inspectors also examined air monitoring 

locations and observed the measurement of geotechnical parameters.
7

During the afternoon of October 23, EPA inspectors observed operations in the CH and RH bay areas of 

the waste handling building above ground. On October 24, inspectors accessed the WDS, and were able 

to generate Container and Canister Data Reports for the RH boreholes and CH waste containers 

observed in the underground. Inspectors discussed record-keeping procedures with WDS data 

administrators at the Carlsbad Field Office, and NWP personnel generated additional reports and queries 

related to the emplacement of shielded containers in Room 2 of Panel 6 for the inspectors. EPA 

presented its preliminary observations at a close-out meeting on the afternoon of October 24.

5.0 Waste Emplacement/WDS

 Wastes received at the repository include contact-handled (CH) transuranic wastes from Argonne

National Laboratory-East (ANL-E) in Illinois, Bettis Atomic Power Laboratory, GE Vallecitos Nuclear 

Center, Lawrence Livermore National Laboratory, Sandia National Laboratory, Los Alamos National 

Laboratory (LANL), Idaho National Laboratory (INL), Hanford Site in Washington, Rocky Flats 

Environmental Technology Site (RFETS), Savannah River Site (SRS), the Nevada Test Site (NTS), and 

the Oak Ridge National Laboratory (ORNL) in Tennessee. These wastes are received and emplaced in 

several configurations: Standard Waste Boxes (SWBs), 55-gallon drums assembled in groups of seven 

called a Seven Pack, 100-gallon drums for super compacted waste, Ten Drum Overpacks (TDOP), SLB2

containers, and Shielded Containers. RH wastes from INL, ORNL, ANL-E, and SRS have been 

emplaced in the WIPP, using the 72-B canister.

The repository is subdivided into panels, each panel consisting of seven rooms. At the time of the 

inspection, CH waste was being emplaced in Panel 6, Room 1 and RH waste in the walls of Panel 7, 

Room 7. CH waste containers are stacked in columns (waste stacks) combining SWBs, drum packs, and 

TDOPs (see Figures 2 and 3). TDOPs are always placed on the floor of the room, occupying the bottom 

and middle position of a waste column. SWBs and drums may be emplaced in any 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 2). RH waste is 

placed in the walls on eight foot centers (Figure 5).
8

Figure 1

Typical RH and CH TRU mixed waste disposal configuration
9

 

Figure 2

Arrangement of Disposed Waste in a Room

Figure 2 illustrates the arrangement of disposed contact-handled waste in underground. 

Represented are stacks of seven-packs of drums and standard waste boxes. Figure 3 shows the 

waste face in Panel 6 Room 1. The waste face shows three packs of 100-gallon drums, standard 

waste boxes, and an SLB2. In Panel 7, Room 7 inspectors observed boreholes drilled to emplace 

RH containers. The Horizontal Emplacement/Retrieval Equipment set up to emplace a RH 

canister is shown in Figure 4. Figure 5 shows the RH waste boreholes selected for records 

review. Figure 6 shows emplacement of a SLB2 waste container in Panel 6 Room 1. The SLB2

is a container approved for WIPP designed for oversized material.

While underground in Panel 6, Room 1, EPA inspectors selected recently emplaced CH waste 

packages for review. The inspector noted the shipment identification numbers directly off the 

emplaced containers. The containers selected are identified in Table B below.

Table B: 

Waste Containers Reviewed During Inspection

CH Waste Containers

Reviewed During Inspection 

(Panel 6, Room 1)

 Container Number Container Type

WMAPSLB037 SLB2

BN10500159 100-Gallon Drum

BN10495381 Standard Waste Box (SWB)

BN10498135 Ten Drum Overpack (TDOP)

BN10498132 Ten Drum Overpack (TDOP)

RH Waste in Selected

Boreholes (Panel 7, Room 7)

 Container Number Borehole

ID

03

62

03

A 3

E

01

68

03

4

On the morning of October 24 at CBFO, inspectors met with NWP personnel, who 

answered questions and generated the Nuclide Report, Materials Emplacement Report and 
10

the MgO safety factor calculations. All electronic records were found to contain required 

waste stream, container, and emplacement information.

Figure 3

Emplaced waste in Panel 6, Room 1
11

Figure 4

Equipment prepared for RH waste emplacement

Figure 5

Emplaced RH Waste selected for review
12

Figure 6

SLB2 in Panel 6 Room 1

6.0 Magnesium Oxide Backfill

Magnesium oxide (MgO) is the engineered barrier used in the repository as backfill, as 

specified in DOE’s Compliance Certification Application (CCA). EPA requires DOE to 

maintain an MgO safety factor (excess factor) to ensure that adequate MgO is chemically 

available to control the chemistry of each room after closure. The Agency approved lowering 

the required safety factor to 1.2 from 1.67 in a letter dated February 11, 2008, requiring the 

emplacement of sufficient MgO to react with 1.2 times the amount of carbon present in the 

repository. Conditions of EPA’s agreement stipulate that DOE must ensure a minimum 

reactivity of 96% for the MgO emplaced, and maintain the safety factor on a room-by-room

basis. The Department instituted this change in March 2009, and it was a focus of EPA’s 2009 

inspection.

DOE maintains a safety factor of 1.2 on a room-by-room basis. The average reactivity from the 

supplier measured for the 2013 period was 97.4. The average reactivity for the 2012 

emplacement period was 97.6. Both of these manufacturer reactivity’s are above the required 

96%.

Process steps guiding MgO placement and documentation in the underground continue to be 

found in WP 05-WH1025, CH Waste Downloading and Emplacement, and WP-05-WH.02,
13

WIPP Waste Handling Operations WDS User’s Manual. Waste Handling Engineers (WHE) 

may record the quantity and placement of MgO electronically using a WDS bar code reader, or 

manually via paper forms if a bar code reader is unavailable. 

While in the underground repository, EPA inspectors verified that the proper procedures were 

used to track MgO emplacement in Panel 6, Room 1 and that MgO was emplaced on top of the 

CH waste stacks as stipulated. At the conclusion of each shift, the WHE must electronically 

verify the safety factor of 1.2 using the WDS. MgO safety factor calculations made using the 

WDS allowed inspectors to verify that the MgO safety factor was maintained in Panel 6, Room 

1.

Checklist items 12-24 specifically relate to MgO management and demonstrate that DOE has 

appropriate processes in place to ensure that MgO is properly emplaced.

DOE is emplacing waste stacked 2-3 containers high topped with 3000 lb MgO supersacks. 

Figure 3 shows the container types visible during the inspection. Visible on the waste face are 

black 100-gallon drums in 3-packs, smaller white containers are standard waste boxes, and a 

larger white container that is an SLB2. 3000 lb MgO supersacks are visible on top of certain 

waste columns to insure a safety factor above 1.2. 

7.0 Comparison With Inventory Limits

The Nuclide Report and the Emplaced Materials Report provided data for emplaced waste,

including total activities of the ten EPA-tracked radionuclides, total weights of ferrous and nonferrous metals, and the CPR/MgO balance by room, as of October 24, 2013. More detailed data 

on the total amounts of specific materials emplaced was provided by WDS staff.

EPA establishes limits for certain waste components at WIPP by approving performance assessment 

inventory estimates. The limit for ferrous metals is a minimum limit. The amount of ferrous metal

is now 27,083,534 kg. The minimum limit of 20,000,000 kg iron was met for the repository in 

2011. Other waste component limits are maximum limits. Of special concern is the maximum limit 

on the total amount of cellulosic, plastic and rubber (CPR) materials. In the original CCA, DOE 

calculated 2.2 x 10

7

kg of CPR, establishing EPA’s limit. In the subsequent performance assessment 

baseline calculations, DOE added packaging materials to the calculations, and now the CPR limit

for WIPP is 2.4 x 107kg (see Table C). CPR values are tracked on a per container basis and the 

current CPR values as of September 30, 2013 are listed in Table C.

As of this inspection the WIPP contained 6,375,437 kg of CPR in waste and 1,706,567 kg of CPR in 

packaging material. In addition, emplacement CPR, such as the slip sheets used to aid the 

emplacement of the containers, accounts for another 525,682 kg of CPR. This is a total of 

8,738,265 kg of cellulosic, plastic and rubber material. The mass of rubber materials currently 

accounts for approximately 4.2% of the total mass of CPR, compared to 4.2% in 2012, 4.7% in 2011, 

4.3% in 2010, 3.4% in 2009, 5% in 2008, 4.7% in 2007, and 7% in 2006. The WIPP currently 

contains approximately 36% of its maximum limit for CPR. The repository held 34% in 2012, 30% in 

2011, 29% in 2009, 24% in 2008, and 21% in 2007.
14

Table C: Emplaced CPR Quantities as of September 30, 2013

Waste CPR:

Type Weight (kg)

Emplacement CPR:

Type Weight (kg)

------------------------------------ ------------ --------------------

Cellulosic 2,725,574.91 Cellulosic 68,598.43

Plastic 3,286,267.57 Plastic 457,083.70

Rubber 363,594.44

Total 6,375,436.92 (kg) 525,682.13 (kg)

Packaging CPR: MgO CPR:

Type Weight (kg) Type Weight (kg)

----------------------------------- --------------------------------

Cellulosic 9 0 6 ,260.79 Cellulosic 6 2 ,465.70

Plastic 800,306.39 Plastic 68,113.20

Total 1,706,567.18 (kg) 130,578.90 (kg)

Grand Totals:

Cellulosic + Plastic = 8,374,670.69

Rubber = 363,594.44 

Total CPR = 8,738,265.13 (kg)

The Land Withdrawal Act of 1992 limits the total waste to no more than 6.1 million cubic feet and the 

total activity of the RH waste to 5.1 million curies. The emplaced waste as of October 27, 2013 is 89,359 

cubic meters or 3,155,684 cubic feet. The emplaced waste is 52% of the maximum allowed. The RH 

activity is shown in Attachment B as 23,020 curies, which is 0.45% of the maximum allowed.

The Inspection Team reviewed the WDS data for the recently emplaced shielded containers in Panel 6 

Room 2. The dose and alpha activity data for these nine containers is shown in Table D. The shielded 

containers allow WIPP to emplace TRU waste that has higher activity than regular CH waste because 

the lead shielding limits the surface dose on the container to less than the CH standard of 200 mrem/hr.

Table D: WDS Record of Shielded Container Waste

Container Alpha Activity

(Ci)

Neutron Dose

(mrem/hr)

Beta/Gamma Dose 

(mrem/hr)

Total Dose

(mrem/hr)

AE1241SC 1.86E-02 0.5 15.5 16.0

AE1242SC 1.0E-01 0.5 89.8 90.3

AE1243SC 5.41E-02 0.17 58.5 58.67

AE1245SC 4.47E-02 0.11 10.7 10.81

AE1246SC 6.34E-03 0.082 49.3 49.38

AE1247SC 1.12E-01 0.091 120.5 120.59

AE1248SC 1.05E-01 0.15 120.9 121.05

AE1249SC 3.59E-02 0.15 69.1 69.25

AE1250SC 6.12E-03 0.05 4.5 4.55
15

8.0 Summary of Results

The inspectors reviewed emplacement operations, NWP procedures, and records associated with 

selected containers. The surface processing of CH and RH waste as well as underground operations 

were reviewed and found to be adequate, according to specified plans documented in the CCA. EPA 

concludes that DOE’s emplacement activities and records are adequate, and that CPR and MgO are 

appropriately tracked. EPA identified no findings or concerns with the emplacement portion of the 

inspection.
16

Attachment A

WIPP 2013 Inspection Plan for Emplaced Waste As Specified in DOE’s Compliance 

Certification Application and per Requirements Specified in 40 CFR 194.21

Purpose:

The purpose of this inspection is to verify that waste sent to WIPP during the past year has 

been emplaced in the underground facility in the manner specified in DOE’s Compliance 

Certification Application (EPA Air Docket A-93-02, Item II-G-01) and other approvals. 

EPA is performing this inspection under the 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.

Scope:

The scope of this inspection includes: demonstration of the site’s ability to receive, 

process, and emplace contact-handled and remote-handled TRU wastes within the 

repository; the use of magnesium oxide (MgO) backfill in appropriate amounts to fulfill 

DOE commitments and requirements; maintenance of relevant waste packaging records, 

including the electronic WIPP Waste Data System (WDS) and the verification of 

appropriately implemented quality assurance practices. The availability of documentation 

of these processes and activities will be an important part of this review.

Focal Areas of the 2013 Inspection:

What changes have taken place to emplacement activities and documentation since last 

year’s inspection, particularly with regard to the handling and DOE’s modifications since 

the 2012 inspection.

Location:

The inspection will be held at DOE’s WIPP facility located twenty-six miles southeast of 

Carlsbad, New Mexico and the Carlsbad Field Office (CBFO) in Carlsbad. Inspection 

activities will include examination of the underground facilities, review of records related 

to waste emplacement, and other information as needed.

Duration:

The EPA expects to complete its inspection in three days. Each full day will begin with an 

opening meeting at 8:00 a.m. and end no later than 5:00 p.m. with a closeout session. 

Date: October 22-24, 2013

Documents for Review: 

Provide to EPA the latest version of pertinent documentation and/or procedures related to 

CH and RH waste handling and emplacement, MgO emplacement and tracking, and record 

keeping using DOE’s WDS. 
17

Attachment B

Summary Totals WDS Nuclide Report through October 

24, 2013

Panel: ALL Room: ALL

Radionuclide Repository CH Repository RH Total Repository

 Activity (Ci) Activity (Ci) Activity (Ci)

AM-241 Americium 241 2.532E5 6.083E2 2.538E5

CS-137 Cesium 137 1.411E1 1.389E4 1.39E4

PU-238 Plutonium 238 4.794E5 6.956E2 4.801E5

PU-239 Plutonium 239 3.297E5 3.701E2 3.301E5

PU-240 Plutonium 240 8.146E4 2.719E2 8.173E4

PU-242 Plutonium 242 2.683E1 3.724E-1 2.72E1

SR-90 Strontium 90 1.58E1 7.181E3 7.197E3

U-233 Uranium 233 6.505E0 3.842E-1 6.889E0

U-234 Uranium 234 8.623E1 1.082E0 8.731E1

U-238 Uranium 238 1.741E1 3.817E-2 1.744E1

Totals: 1.144E6 2.302E4 1.167E6
18

Attachment C

Materials Emplaced in WIPP as of September 30, 2013

Hand

Code MP Material Type Material Description

Material

Weight

(kg)

Packaging

CPR

(kg)

Emplaceme

nt

CPR

(kg)

MgO

CPR

(kg)

Total

CPR

(kg)

CH 1 Waste IRON BASE METAL ALLOYS 10,696,778.53

2 Waste ALUMINUM BASE METAL/ALLOYS 59,300.51

3 Waste OTHER METAL/ALLOYS 354,312.32

4 Waste OTHER INORGANIC MATERIALS 1,752,818.10

6 Waste CELLULOSICS 2,725,574.91 2,444,259.42

7 Waste RUBBER 363,594.44 350,661.13

8 Waste PLASTICS 3,286,267.57 3,150,687.26

9 Waste SOLIDIFIED INORGANIC MATERIAL 7,891,393.37

10 Waste SOLIDIFIED ORGANIC MATERIAL 2,691,696.71

12 Waste SOILS 656,923.42

13 Steel Packaging STEEL CONTAINER MATERIALS 15,803,195.73

14 Plastic Packaging

PLASTIC/LINERS CONTAINER 

MATERIALS 800,306.39 762,828.30 762,828.30

15 Cellulosic Packaging

CELLULOSICS PACKAGING 

MATERIALS 906,260.79 881,508.36 881,508.36

18 Emplacement

CELLULOSIC EMPLACEMENT 

MATERIAL 68,598.43 63,301.83 63,301.83

20 Emplacement PLASTIC EMPLACEMENT MATERIAL 457,083.70 431,716.00 431,716.00

21 Steel Liners STEEL LINER MATERIALS 582.70

22

Non-Ferrous 

Packaging LEAD PACKAGING MATERIAL 13,150.10

99 Emplaced Dunnage STEEL DUNNAGE CONTAINERS 170,737.50

RH 1 Waste IRON BASE METAL ALLOYS 80,344.89

2 Waste ALUMINUM BASE METAL/ALLOYS 29.20

3 Waste OTHER METAL/ALLOYS 9.72

4 Waste OTHER INORGANIC MATERIALS 13.06

6 Waste CELLULOSICS 360.22 274.62

7 Waste RUBBER 7.30 7.30

8 Waste PLASTICS 68,004.23 59,711.22

9 Waste SOLIDIFIED INORGANIC MATERIAL 194.67

10 Waste SOLIDIFIED ORGANIC MATERIAL 15.06

13 Steel Packaging STEEL CONTAINER MATERIALS 380,690.96

14 Plastic Packaging

PLASTIC/LINERS CONTAINER 

MATERIALS 770.40 403.86

15 Cellulosic Packaging

CELLULOSICS PACKAGING 

MATERIALS 16.86 4.26

21 Steel Liners STEEL LINER MATERIALS

 

147

.60

MgO 16 Emplacement MAGNESIUM OXIDE 32,349,740.38

18 Emplacement

CELLULOSIC EMPLACEMENT 

MATERIAL 62,465.70 59,464.20 59,464.20

20 Emplacement PLASTIC EMPLACEMENT MATERIAL 68,113.20 65,111.70 65,111.70

Totals: 81,709,498.67 495,017.83 124,575.90 8,269,939.46
19

Attachment D

Procedures Examined

05-WH.02 Rev.2 WIPP Waste Handling Operations WD User’s Manual

D-0101 Rev 8 Specification for Prepackaged MgO Backfill

WP 05-WH1010 Rev.8 Container Overpacking

WP 05-WH1705 Rev.10 RH Canister Transfer System

WP 05-WH1709 Rev.15 RU TRU 72-B Trailer Unloading

WP 05-WH1710 Rev 24 72-B RH Processing

WP 05-WH1716 Rev 4 CNS 10-160B Cask Operation

WP 05WH1717 Rev 8 Cask Unloading Room Shield Door Operation

WP 05-WH1725 Rev 10 RH Waste Downloading and Emplacement

WP 05-WH1758 Rev 15 RH Waste Handling Abnormal Operations

WP 08-NT 01 Rev 27 Waste Data System Program and Data Management Plan

WP 08-NT 03 Rev14 Waste Stream Profile Form Review and Approval Program

WP 08-NT 04 Rev 21 Waste Data System Configuration Management and Software Quality Assurance 

Program

WP 12-HP1314 Rev 7 Remote Handled Waste Service Room
20

Attachment E

EPA Emplacement Inspection Checklist

October 22 – 24, 2013

Questions: Comments and Objective Evidence Results

Waste Emplacement Sat = Satisfactory

1 Is waste being emplaced in

the underground facility in the

manner specified in DOE’s

Compliance Certification/ ReCertification or other relevant

documentation?

Yes. Procedure WP 05-WH1025, CH Waste

Downloading and Emplacement, Section 2, describes

the CH emplacement procedures. Visual verification

of the emplaced waste in Rows 7 through 8 of Panel 6,

Room 1 confirmed waste emplacement in accordance

with facility procedure and CCA documentation .

RH processing procedures for 72-B (WP 05-WH1710,

WP 05-WH1725) and 10-160-B (WP 05-WH1722) 

containers are consistent with the approach discussed

in the CCA documentation. Emplacement in the 

repository walls with borehole plugs was verified

during inspection of the underground.

Sat

2

Are CH waste containers stacked

in columns appropriately

given the type of container?

Yes. In WP 05-WH1025, CH Downloading and

Emplacement, a note at step 2.25 specifies appropriate

stacking of CH container types. Attachment 2 of the 

same procedure specifies payload assembly

positioning. Visual verification confirmed adherence

to procedure (e.g. TDOPs placed in bottom position of

waste columns.)

Sat
21

3 Are records adequate?

Randomly select 3-4 CH and 2-3

RH waste containers to verify

records for waste approval,

shipment, and receipt.

Yes. TRU Waste Receipt WP 08-NT3020, describes

the process. Records produced are Uniform

Hazardous Waste Manifest, TRU Waste Receipt

Checklist, Shipment Summary Report, RH waste

Processing Data Sheet, Radiological Survey Report,

and Waste Emplacement Report. CH waste produces

comparable records. EPA reviewed records and found

the records to be adequate and traceable.

Selected Containers:

CH Waste (Panel 6, Room 1, Rows 7 – 8)

- SLB2 - WMAPSLB037

- 100-Gallon Drum - BN10500159

- Standard Waste Box (SWB) - BN10495381

- Ten Drum Overpack (TDOP) - BN10498132

- Ten Drum Overpack (TDOP) - BN10498135

RH Waste (Panel 7, Room 7)

- Borehole 033, ID0362 (RH CANISTER WITH 

REMOVABLE LID-OVERPACK – 1, 55-gallon drum)

RH Waste (Panel 7, Room 7)

- Borehole 034, AE0168 (RH CANISTER WITH 

REMOVABLE LID-OVERPACK – 3, 30-gallon 

drums)

Sat

4 Is DOE properly emplacing

backfill material (magnesium

oxide [MgO]) with the waste

packages?

Are supersacks placed on top of

waste stacks according to

procedure?

Yes. 3000-pound supersacks were observed to be

emplaced on top of each waste assembly at the active

waste face in Panel 6 Room 1, Rows 7-8.

WP 05-WH1025, CH Waste Downloading and

Emplacement, Section 3.0, establishes procedure for

emplacement of MgO.

Sat

5 Verify documentation for the

containers listed in item 3 - 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

engineered barrier [MgO].

Inspectors examined paper records maintained

underground and electronic records kept aboveground

for the selected containers. Documentation was

determined to be adequate.

Sat
22

RH Waste

Emplacement Questions

6 Are RH containers approved for

receipt, received, processed, and

emplaced properly?

Yes. Inspection of the underground and RH handling

area showed procedures to be in agreement with WP

05-WH1710, 72-B RH Processing, and WP 05-

WH1725, RH Waste Downloading and Emplacement.

Sat

7 Are RH containers appropriately

tracked?

Where is the information?

--In the WDS, what report

--During the receipt/transfer

process where is it recorded?

--In the underground?

Yes. Appropriate information is found in the WDS

Canister Data Report, and on the underground facility

map maintained by the Waste Handling Engineers in

the underground.

Sat

8 Content of RH canisters

--pick 1 to 3 canisters

See Item 3 above. The Canister Data Report was

generated and reviewed for each canister.

Sat

9 Volume and mass and/or

concentration of important waste

components and radionuclides

(RH and CH)?

Are they within statutory and

regulatory limits?

Detailed description of nuclide information is included

in the Waste Container Data Reports and Canister

Data Reports generated.

Yes.

Sat

10 Are RH boreholes closed

properly?

(Note: also see #9 for tracking of

RH in the U/G)

Recently emplaced borehole plugs, and plugs prepared

for emplacement, were observed by inspectors in the 

underground to be in accordance with WP 05-

WH1725, RH Waste Downloading and Emplacement.

Sat

11 Is a photographic record made of

the RH canister number during

emplacement and retained in the

permanent record?

No. The canister ID number is verified by two

operators during cask transfer, via closed-circuit

television in accordance with procedure 05-WH1710,

72-B RH Processing, Section 8.24. Tapes are

maintained for one year, and WP

05-WH1710 Att. 1, RH Waste Processing Data Sheet,

then becomes the permanent record. EPA finds this to 

be adequate.

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Question: Procedures
23

12 Do DOE procedures reflect an

MgO safety factor to 1.2?

Yes. WP 05-WH1025, CH Waste Downloading

and Emplacement, Rev. 1, Section 3.0, Backfill, 

establishes procedures to maintain a safety factor of

1.2 or greater per room on a daily basis. Procedures in 

the WDS User’s Manual, WP-05-WH.02, Sections 

6.2.5, 9.5.3, and Attachment 1 reflect the 1.2 safety 

factor and the use of 3,000-lb. supersacks as 

necessary. WHEs were observed to be using current 

procedures and the WDS bar code reader to record

MgO emplacement in the underground.

Sat

13 Are both CPR and MgO 

calculated and tracked on a 

room- by-room basis?

Yes. Calculations are performed by the Waste

Handling Engineer at the conclusion of each shift, 

through the WDS, using the MgO Balance Report or 

Daily Report, as required by WP 05-WH1025, CH 

Waste Downloading and Emplacement, Rev. 1, 

Section 3.0, Backfill.

Sat

14 Are sampling and analytical 

procedures in place to ascertain 

that emplaced MgO maintains a 

minimum of 96% reactivity?

Yes. Specification D-0101, Prepackaged MgO

Backfill, and WP 05-WH1105, MgO Sample Records 

Management, set forth analytical and document 

management procedures to verifying that each 

shipment of MgO maintains a 96 +/- 2% reactivity.

Average reactivity from the Supplier for 2012 was 

97.6% and currently for 2013 is 97.4%

Sat

15 Is the acceptance of the MgO 

backfill material from the 

supplier documented?

Yes. WP 05-WH1105, MgO Sample Records

Management, Sec. 2.0 requires each shipment to be 

numbered, and the MgO supplier to provide an 

Analysis of Shipment and a sample under Chain of 

Custody for each shipment. Supersacks in the 

underground were observed by inspectors to be 

marked with unique ID numbers, traceable to their 

original shipments.

Sat

16 For the MgO needed for high 

CPR, are there procedures or 

documentation for the WHE or 

WHM (or other appropriate 

personnel) identifying when and 

where additional MgO is needed?

Yes. General procedures are found in the WIPP

Waste Handling Operation WDS User’s Manual, WP

05–WH.02, Attachment 1, Special Requirements for 

Additional MgO. Section 3 of WP 05-WH1025 

calls for notification of the WHM if daily reports 

show the MgO safety factor of a room to be less than 

1.2.

Sat
24

17 Is there documentation that 

identifies how MgO should be 

placed with high CPR waste?

Yes. WP 05-WH1025, CH Waste Downloading and 

Emplacement, Attachment 3, Supersack/BRT 

Emplacement Data Sheet; and WP 05-WH1058, CH 

Waste Handling Abnormal Operations, Sec. 4.0, BRT 

Emplacement

Sat
25

18 Verify documentation of 

procedures for abnormal 

operating conditions, and 

documentation of training for 

contingencies.

Abnormal operating and emergency procedures were 

reviewed, including but not limited to those listed 

below.

WP 04-CO, Conduct of Operations, identifies 

notification policies, supervision and training 

procedures, and required reading (Management 

Policy 1.30).

WP 02-EC3506, Environmental Incident Reporting, 

is the Management Control Procedure for reporting 

releases, and includes statutory requirement charts for 

notifications and decision flowcharts.

WP 05-WH1058, CH Waste Handling Abnormal 

Operations, includes instructions for recovering from 

a torn slip sheet, moving emplaced waste, returning 

waste to surface, and emplacing BRTs. Specifies that 

“Abnormal operations of a large scope (e.g. overpack 

and retrieval) will have specific plans developed.”

WP 05-WH1758, RH Waste Handling Abnormal 

Operations, includes instructions for operating the 

Hot Cell Crane in response to a hoist, trolley, bridge 

or grapple failure, installing and removing the Waste 

Transfer Machine Assembly (WTMA) wheels, 

retrieving a loaded RH –TRU 72-B Cask from the 

Transfer Cell, returning a loaded 10-160B Cask to a 

generator site and resetting the Transfer Cell Light 

Curtain.

WP 12-9, WIPP Emergency Management Program, is 

the top-level document outlining emergency response 

procedures and responsibilities, includes training 

requirements for response roles.

WP 05-WH4401, Waste Handler Operator Event

Response, includes alarm, alert, and exit procedures.

WP 12-ER3906, Categorization and Classification of 

Operational Emergencies includes tables of 

procedures for emergency notifications and 

classification of events.

WP 12-HP4000, Emergency Radiological Control 

Responses, provides guidance for responding to an 

actual or suspected breach of a TRU container, 

contamination found outside controlled areas, 

radiation levels exceeding the limits set in WP 12-5.

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Question: Records/WDS
26

Do the characterization module,

certification module, shipping 

module, and inventory module 

adequately record required 

information?

Reports available through the EPA Dashboard 

contain the container number, shipment number, 

emplacement data and underground location. EPA 

staff queried the WDS to verify that this information 

is recorded correctly.

Sat

19 Does the WDS adequately

document waste shipment and 

emplacements information for 

waste containers selected? (Item 

3 above) CH, RH

Yes. Canister, Overpack, and Container Data Reports

were retrieved, all of which correctly reflected 

container number, shipment number, and 

emplacement information in the underground.

Sat

20 Do records verify that contact 

handled waste container surface 

doses fall within statutory 

requirements? Where are CH 

surface dose records maintained?

Yes. CH surface dose measurements are recorded in

the Container Data Report. Dose limits for each of the 

containers examined by EPA inspectors (listed in 

Item 3) were below statutory limits.

Sat

21 Review a Waste Container Data

Report. Does this report 

adequately record the Waste 

Stream Profile Form 

information?

Yes. For all containers inspected, inspectors found

Container and Canister Data Reports to contain Waste 

Stream IDs, as well as all necessary radiological and 

chemical profile information.

Sat

22 Review the Shipment Summary 

Report. Does the report correctly 

record the containers shipped? 

CH, RH

By querying the Shipment number, the Shipment 

Data report may be generated. Inspectors verified that 

the report reflects the containers shipped.

Sat

23 Review the Waste Emplacement 

Report. Does this report 

adequately record the date of 

receipt, and disposal locations of 

containers? CH, RH

Yes. See Item 21. Sat

24 Is DOE assuring that the 1.2 

safety factor being maintained on 

a room basis?

Does the WDS accurately 

calculate the safety factor and 

recommend the proper amount of 

MgO to emplace?

Yes. See questions 12-17.

EPA inspectors reviewed InSEI Matrix Requirements 

WWIS2-REQ-2126 and -2127 to verify that the WDS 

software calculates MgO excess appropriately.

Sat