DOCKET NO: A

- 98

- 49

Ite m : II

- B3

- 127



### 201 3

– Emplacement Inspection Report

EPA INSPECTION No. EPA

- W IPP

- 10.13

- 22c

OF THE

WASTE ISOLATION PILOT PLANT

October 22

– 24, 2013

U. S. ENV I RONMENTAL P R OTECTION AGENCY

Office of Radiation a n d Indoor Air

Center for Waste Ma n agement a n d Regulation

1200 Pennsylvania Avenue, NW

Washington, DC 20460

January 20142 Table of Contents

1.0 Executive S u m m ary.....................................................................

...... 4

2.0 Inspection P urpose and Scope.............................................................

.... 4

3.0 Inspection T ea m , Observers and Participants..........................................

... 5

4.0 Perfor m ance of the Inspection.............................................................

. 6

5.0 Waste E mp l ace m ent / WDS...............................................................

... 7

6.0 Magnesium Oxide B ackfill................................................................. 12

7.0 Co mparison with Inventory li m its.......................................................... 14

8.0 Sum m ary of Re sults..........................................................................1 5

Attachments

Attach m ent A

– Inspection Plan....................................................................... 16

Attach m ent B

– Sum m a r y of Nuclide report t hrough October 24, 2013......

....... ........... 1 7

Attach m ent C

- Materials E mplaced in W IPP as of September 30, 2013...

......... ... ........ 1 8

Attach m ent D

– Procedures Exa m ined................................................................ 1 9

Attach m ent E

– Inspection Checklist................................................................. 20

Tables

Table A Inspection P articipants...............................................................

. . 5

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

... 9

Table C E m

placed CPR Quantities as of .................................................. ...1 4

Table D WDS Record of Shielded Container Waste

................................. ... ... ..1 4

Figures

Figure 1 Typical RH and CH TRU Mixed W a ste Disposal Configuration ............

... 8

Figure 2 Arrange m ent of di s posed waste in a room

......................................... 93

Figure 3 Photo of disposed waste in Panel 6 Room 1

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

Figure 4 Equip m ent prepared for RH waste emplace m ent...

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

Figure 5 E m

placed RH W aste selected for re v i ew................................

. .............1 1

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

..................... ... .... ........................ . 1 24

1.0 E xecutive Summary

The U.S. Environ m ental Protection A gency (EPA or the Agency) conducted an inspection of the U.S.

Depart m ent of Energy’s (DO E ) W aste Isol a tion Pilot Plant ( W I PP) near Carlsbad, New Mexico, from

October 22 through October 24 , 201 3 , in acc o rda n ce with 40 C FR 194.21. The W IPP is a disposal

facility for defense

- r e lat e d trans u ranic (TRU) waste as defined by the W I PP Land W i thdrawal Act

. 1

EPA first certified that W IPP co m plies 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 deter m ine that waste sent to W I PP during the past year has

been e m placed in the undergrou n d facility in the m anner specified in DOE’s Compliance Certi f ic a tion

Applicati on and other approvals. T he inspection reviews t h e site’s ab ility to re c eive, process, and

e m place contact

- handled and re m ote

- h andled TRU wastes within t h e repository, the e mplac e m ent of

m agnesium oxide (MgO) backfill in appro p riate a m ounts to fulfill D O E com m i t m ents and

require m ents, and the m aintenance of records pertaining to waste shipping, packaging, and

e m plac e m ent, including the electronic W aste Data System (WDS). E P A exa m ined sele c t ed a c tivities,

such as RH and CH wa st e processi n g, waste emplace m ent acti v ities, and record k ee p ing.

EPA concluded that DOE’s e m place m ent activities are adeq u ate, t h at cellulosic, p l astic and rubber

m aterial (C P R) is appro p riately trac k ed and rec o r d ed, that MgO balances a r e calculated properly, and

that MgO is e mplaced properly. The Agency observed the u s e of the proper waste e m placement

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

1 W I PP L an d W ithdr a wal Act, P u blic Law 10 2

- 5 7 9

, Secti o n 2 (1 8 ), as a m ended by t h e 1 99 6 W I PP L WA

A m end m ents, P u blic Law 10 4

- 2 0 1

.

2.0 I nspection Purpose and Scope

The purpose of this annual inspection is to ver i fy that contact

- handled ( C H) and re m o te

- handled (RH)

trans u ranic (TRU) waste sent to W IPP during the past y ear has b een e m placed in the under g round

f acility in t h e m anner speci f i ed in D O E’s Co m

pliance Certification Applicat i on (EPA Air Docket

A

- 93

- 02, Item II

- G

- 01) and other approvals. EPA perfor m ed this inspection under the authority of 40

CFR 194.21, which authorizes the Agency to inspect W I PP during its operational period to verify

continued co m

pliance with EPA’s W I PP Compliance Criteria and the certification decision of May 18,

1998. E m place m ent of waste a nd backfill, in particul a r, is r e leva n t to co m pliance because t h e

e m placement m ethod supports the m o dels that DOE uses in the W IPP perfor m ance assess m ent.

Activities w ithin the sc o pe of this i n spection in cl uded: de m o nstr a tion of the W IPP site’s ability

to receive, p rocess, and e m place remote

- handled (RH) and contact

- ha n dled (CH) TRU wastes within t h e

repository, the use of m agnesium oxide (MgO) b ack f ill in amounts to fulfill c e rtification requirements

and other approvals, m aintenance of rele v ant wa s t e packa g ing records, including t h e electro n i c W a ste

Data System ( W DS) and the ve r i f i cation of appropri a tely i m ple m ented quality ass u ran c e pra c tic e s. The

review and exa m ination of docu m ents related to the s e a c tivities is an i mporta n t pa r t o f the inspe c tion

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

m ajority of waste related activities onsite are describ e d by or controlled through NWP procedures. A list

of NWP procedures exa m ined during this inspection is provided i n Attach m ent D

.5

3.0 I nspection Team, Observers and Participants

The inspection team consisted of t h ree EPA sta f f. Trais Kliphaus of the New Mexico Environment

Department observed the ins p ection acti v ities. A parti a l list of inspe c tion participants is provided in

Table A.

Table A

Inspection Parti c ipan t s

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 NWP6

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 O ffice (CBFO)

and at the W aste Isol a tion P ilot P l ant ( W IPP) facility, which is located approxi m ately 26 m iles south east

of Carlsbad, N ew Mexico. The opening m eeting with CBFO and NWP personnel was held on the

m orning of October 22, 2013

. Facility s taff presented in f or m ation addressing program status, up d ates

and cha n ges since the last EPA emplace m ent inspection which took place from July 17 to July 19, 2012

. The pri m ary focus of the e mplace m ent ins p ection was to d eter m ine the nature and extent of changes that

had ta k en place in the areas of emplace m ent acti v ities a n d docu m en t ation s i nce last year’s inspection

.

EPA inspectors acco m

panied CBFO and NWP p e rsonnel into the under g r o und reposit o ry on the

morning of October 23 , in o rder to examine waste pa cka g es and MgO that had been e mplaced in Panel

6. Inspectors reviewed records documenting that waste e m place m ent and MgO tracking were conducted

in accorda n ce with procedures. Ins p ectors selected several c o ntainers and recor d ed their nu m bers (see

Figure 3 ), the rec o rds for these c ontainers were exa m ined both in t he repository and later using the W D S

co mputer database, to verify correct waste infor m ation is recorded by DOE. NWP personnel ans w ered

EPA questions about how was t e is handled and e m placed. The inspectors also exa m ined air monitoring

l o c a tions and observed the m easure m e nt of geotechnical para m eters.7

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

the waste ha ndling buil d ing above ground. O n October 24 , inspectors accessed the W D S, and were able

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

observed in the underground

. I nspectors discussed record

- keeping procedures with W D S data

ad m i nis t rat o rs at the Carlsbad Field Office, and NWP personnel generated additional repor t s and queries

related to the emplacement of shielded containers in Room 2 of Panel 6 for the inspectors. E P A

presented its preli m inary observations at a close

- out m eeting on the afternoon of October 24

.

5.0 W aste Emplacement/WDS

Wastes received at the repository include conta c t

- handled ( C H) 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, L os Ala m os National

Laboratory ( L ANL)

, Idaho National Laboratory (INL), Hanford Site in W ash i ngton, R ocky Flats

E nviron m ental Tec hnology Site (RFETS) , Savannah River S i te (SRS) , the Nevada Test Site (NTS) , and

the Oak Ridge National L a boratory (ORNL) in Tennes see. These wastes are received and e mplaced in

several configuration s : Standard Waste Boxes (S W Bs), 55

- gallon d rums asse m bled in groups of seven

called a Seven Pack, 100

- gallon dru m s for super co m pacted waste, Ten Dr u m Overpacks (TDOP)

, SLB2

containers , and S hielded C ontainers

. RH wastes fr o m INL, ORNL, ANL

- E, and SRS have been

e m placed in the W IPP, using the 72

- B canister.

The repository is subdivided into panels, each p a nel consisting of seven roo m s. At the ti m e of the

ins p ecti o n, 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 colu mn s (waste stacks) combining S W Bs, drum pa c ks, and

TDOPs (see Figures 2 a n d 3). TDOPs are always placed on the floor of the roo m , o c cupying the bottom

and m i ddle position of a waste col u mn. SWBs and d r u m s m ay be e mplaced in any order, with most

wastes e mplaced as received. The waste c o lu m n s 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 f oot centers (Figure 5 ).8 Figure 1

Typical RH and CH TRU m i xed w a ste disposal configuratio n9 Figure 2

Arrange m ent of D i s posed W aste in a R oom

Figure 2 i llustrates the arrange m ent of disposed contact

- h andled waste in underground.

Represented are stacks of seven

- packs of dru m s 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 a n SLB2

. In Panel 7 , Room 7 inspectors o b served bor e holes drilled to e mplace

RH contai n ers. The Horizontal E mplace m ent/Retrieval Equip m ent set up to e m place a RH

canister is shown in Fig ur e 4

. Figure 5 shows the RH waste boreholes sel ected for records

review. Figure 6 shows emplacement of a SLB2 waste container in Panel 6 Room 1. T he 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. T h e inspector n oted the shi p m ent identi f ication numbers d i rectly off the

emplaced co n t ainers. The containers selected are identified in Table B below.

Table B:

Waste Containers Revie w ed During Inspection

CH Waste Containers

Revie w ed During Inspection

(Panel 6, Room 1 ) Container Number Container Type

WMAPSLB037 SLB2

BN10500159 100

- G al lon Drum

BN10495381 Standard Waste Box ( S WB)

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 0 3

3 A

E

01

68 0 3

4

On the m orning of October 24 at CBFO, inspectors m et with NWP personnel, who

answered questions a n d generated the Nucli d e Report, Materials E m place m ent Report and10

the M g O safety factor calculations. All electronic records were found to contain required

waste strea m , container, and e m plac e m ent infor m ation.

Figure 3

Emplaced waste in Pa n el 6 , Roo m 111 Figure 4

Equip m ent prepared for RH waste emplace m ent

Figure 5

E mplaced RH W aste selected for re v i ew12 Figure 6

SLB2 in Panel 6 Room 1

6.0 Magnesium Oxide Backfill

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

specified in DOE’s Co m pliance C erti f ication Ap plication (CCA). EPA requires DOE to

m aintain an M g O sa f

ety factor (e x cess factor) to ensure t h at adequate M g O is che m ically

a v ailable to control the che m istry of each room after clos u re. The Agency approved loweri n g

the req u ired safety factor to 1.2 fr o m 1.67 in a letter dated Febr u ary 11, 200 8 , requiring the

e m place m ent of sufficie n t MgO to react with 1.2 ti m es the a m ount of c arbon pre s ent in t h e

re p ository. C o nditions of EPA’s agree m ent stipulate that DOE must ensure a m i ni m u m

reactivity of 96% for the MgO e m placed, and m aintain the safety factor on a ro o m

- by

- room

basis. The Department instit u ted t h is change in March 2009, a n d it was a focus of EPA ’ s 2009

inspection.

DOE maintains a sa fety factor of 1.2 on a room

- by

- room basis. The average reactivity from the

supplier measured for the 2013 period was 97. 4

. T he average reactivity for the 2012

emplacement period was 97.6

. Both of these manufacturer reactivity’s are above the required

96%.

Process ste p s guiding MgO place m e nt and doc u m entation in the under g round conti n ue to be

found in W P 05

- WH1025, CH Waste Downloading and Emplacement , and WP

- 05

- W H.02,13

WIPP Waste Handling Operations WDS User’s Manua l

. Waste Handling Engineers ( W HE)

m ay record the q uantity and place m ent of MgO electronically using a W DS bar code rea d er, or

m anually via paper fo r m s if a bar code reader is unavailable.

W hile in the underground repository, EPA i n spectors verified that the proper procedures were

used to track MgO e mplace m ent in Panel 6 , Room 1 and that MgO was e m placed on top of the

CH waste stacks as stip u l ated. At the c o nclusion of each shift, the W H E must electronically

v e rify the safet y factor of 1.2 using the WDS. MgO safety factor calculations m ade using the

W D S allowed inspectors to verify that the MgO saf e ty factor was m aintained in Panel 6 , Room

1

.

Checkli s t it e m s 12

- 24 speci f i c ally rel a te to MgO m anage m ent and de m onstrate that DOE has

appropriate processes in place to ensure t h at MgO is properly e m placed.

DOE is e mplacing waste stacked 2

- 3 containers high topped with 3000 lb M gO s upersacks.

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

black 100

- gallon dru m s in 3

- packs, small e r white c ontainers are standard waste boxes, and a

larger w hite container that is an SLB2. 3000 lb M g O supers acks 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 e m placed waste,

i ncluding total a cti v ities of the ten EPA

- trac k ed radionuclides, total weights of ferrous and non

ferrous m etals, and the CPR/MgO balance by room, as of October 24, 2013

. More detailed d ata

on the t o tal a m ounts of specific m aterials e m p laced was provided by WDS staff.

EPA establishes li m its for certain w aste co mponents at W IPP by approving perfor m a nce assess m ent

inventory esti m ates. The limit for ferrous metals is a minimum limit. The a m ount of ferrous metal

is now 2 7

, 083

, 534 kg. The m i n i m u m li m it of 20,000,000 kg iron was m et for the repository in

2011 . Other waste co mponent li m its are m ax i m u m li m its. Of special concern is the m ax i m u m li m it

on the total a m ount of cellulosic, p l astic and rubber (CPR) m aterials. In the original CCA, DOE

calculated 2.2 x 1 0 7 kg of CPR, establishing EP A ’s li m it. In the subsequent perfor m ance assess m ent

baseline calculations, D O E added packa g ing m aterials to the calculations, and now t he CPR li m it

f or W IPP is 2.4 x 10 7 kg (see T able C). CPR values are trac k ed on a per co n t ainer basis a n d the

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

.

As of this inspection the W I PP conta i ned 6, 375

, 437 kg of CPR in waste and 1, 706,567 kg of CPR in

packa g i n g m aterial. In addition, emplace m ent CPR, such as the slip sheets used to aid the

e m place m ent of the contai n ers, accounts for another 525

, 682 kg of CPR. This is a total of

8,738,265 kg of cellulosic, plastic and rubber m aterial. The m a ss of rubber m aterials currently

accounts for approxi m ately 4. 2 % of the total m ass 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 W I PP currently

contains approxi m ately 3 6 % of its m ax i m u m li m it 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 ,5 74

. 91 Cellulosic 6 8

, 598

. 43

Plastic 3,2 86

, 267

. 57 Plastic 457

, 083

. 70

Rubber 3 63

, 594 .4 4

Total 6, 375

, 436 .9 2 (kg) 525

, 682

. 13 (kg)

Pac k aging CPR: MgO CPR:

Type Weight (kg) Type W eight (kg)

----------------- - -------------- - -- ------------ - ------------ - ------ Cellulosic 9 0 6

, 260

. 79 Cellulosic 6 2

, 465.70

Plastic 800

, 306

. 39 Plastic 6 8 ,11 3

. 2 0

Total 1, 706

, 567

. 1 8 (kg) 1 30

, 578 .90 (kg)

Grand Totals:

Cellulosic + Plastic = 8

, 374

, 670

. 69

Rubber = 3 63

, 594 .4 4

Total CPR = 8, 738

, 265

. 13 (k g)

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 c ontainers 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 Contain er 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 0.1 5 69.1 69.2 5

AE1250SC 6.12E

- 03 0.05 4.5 4.5515

8.0 Summary of Results

The inspectors reviewed e m plac e ment operation s

, NWP procedures, and records as s ociated with

selected co n t ainers. The surface pr o cessing of CH and RH waste as well as undergr o und operati o ns

were reviewed and found to be adequate, accord i ng to specified plans docu m ented in the CCA. EPA

concludes t h at DOE’s e mplace m ent acti v ities a n d r ecords are adequate, and that C P R and MgO are

appropriately trac k ed. EPA identified no findings or concer n s with the emplace m ent 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 empla ced 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 implemente d 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 Fi eld 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. a nd 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 empl acement and tracking, and record

keeping using DOE’s WDS.17 Attachment B

Summary Totals WDS Nuclide Report t hrough October

24, 2013

Panel: ALL Room: ALL

Radionuclide Repository CH Repository RH Total Repository

Activity (Ci) Act ivity (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. 1 44E6 2.302E4 1.167E618 A ttachment C

Materials Emplaced in WIPP as of September 30, 2013

H and

Code M P 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 8,269,939.4619 A ttachment D

Procedures Examined

05

- WH.02 Rev.2 WIPP Waste Handling Operations WD U ser’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 Re v14 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 Room20 A ttachment E

EPA Emplacement Inspection Checklist

October 22

– 24, 2013

Questions: Comments a nd Objective Evidence Results

Waste E m placement Sat = Satisfactory

1 Is was t e being e m

pl a ced i n

the underground facility in the

manner spec i fied in DOE’s

C o m p liance Certification/ Re

Certification or other rele v ant

docu mentati o n? Yes. Procedure WP 05

- W H1025, CH Waste

Downloading and E m

pla ce ment, Section 2, describes

the CH e m

pl a c e ment procedures. Visual verification

of the e m placed waste in Rows 7 th ro ugh 8 of Panel 6

, Ro o m 1 confirmed waste e m placement in accordance

with facility procedure and CCA docu mentati o n

.

RH processi n g procedures for 72

- B (WP 05

- WH1710,

WP 05

- WH 1 725) and 10

- 160

- B (WP 0 5

- WH1722)

containers are consistent with the appro a ch discussed

in the CCA documentation. E m placement in t h e

reposito r y walls with bore h ole plugs was verified

during inspection of t h e u n dergrou n d. Sat

2 Are CH was t e containers s tacked

in colu m n s appropriate l y

given the t y pe of c o ntainer? Yes. In WP 05

- WH10 2 5, CH Downloading a n d

E m plac e men t

, a note at step 2.25 specifies appropriate

stacking of CH container types. Attachment 2 of the

s a me procedure specifi e s pa y load ass e mbly

position i ng. Visual verification confirmed adherence

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

waste colu m

n s.) Sat21

3 Are records ad equate?

Rando m ly select 3

- 4 CH and 2

- 3

RH w a ste c o ntainers to verify

records for waste approval,

shipment, and receipt. Yes. TRU Waste Receipt WP 08

- NT3 0 20, describes

the process. Re c ords produced are Uniform

Hazardous Waste Manifes t

, TRU Waste Receipt

Checklist, Shipment Summary Report, RH waste

Processing D ata Sheet, R a diological Survey Report,

and Waste E m

p l ac e ment Report. CH waste produces

c o m p arable r ecords. EPA reviewed re co rds and found

the records to be adequate and traceable.

Selected Containers:

CH Waste ( Panel 6

, Ro o m 1

, Rows 7

– 8)

- SLB2

- WMAPSLB037

- 100

- Gallon Drum

- BN 10500159

- Standard Waste Box (S W B)

- BN10495381

- Ten Drum Overpack (TDOP)

- BN10498132

- Ten Drum Overpack (TDOP)

- BN10498135

RH Waste (Panel 7 , Room 7 )

- Borehole 033

, ID0362 (RH CANISTER W ITH

REMOVABLE LID

- OVE R PA C K

– 1

, 55

- gallon dru m )

RH Waste (Panel 7 , Room 7 )

- Borehole 034 , AE 0168 (RH CANISTER W ITH

REMOVABLE LID

- OVE R PA C K

– 3, 30

- gallon

drums) Sat

4 Is DOE properly e m placing

backfill material ( m agnesi u m

oxide [ MgO ] ) with the waste

packages?

Are supers ack s placed on top of

waste stacks according to

procedure? Yes. 3000

- p o und s u persacks were observed to be

e m pla c ed on top of each waste a ss e mbly at the active

waste f ace in Panel 6 Room 1 , Rows 7

- 8

. WP 05

- WH1025, CH Waste Downloading a n d

E m placement, Section 3.0, establishes p r ocedure for

e m p l ac e ment of MgO. Sat

5 Verify docu mentation for t h e

containers listed in item 3

- waste

generator site trans m

ittal of waste

to WIPP, W I PP approval,

shipment cer t ification for

transport to WIPP, shipment

initiation do c umentation,

shipment rec e ived at WIPP

records, was t e e m

pl a ced in the

undergr o und, and place m e nt of

engineered barrier [Mg O ]. Inspectors ex a m ined paper records m ai n tained

undergr o und and electronic records kept abovegro un d

for the selec t ed containers. Doc u mentat i on was

determined to be adequate. Sat22

RH Waste

Emplac e m e n t Questions

6 Are RH containers approved for

receipt, re c eived, process e d, and

e m placed properly? Yes. Inspection of t h e u nd erground a n d RH handling

area showed procedures to be in agre e ment with WP

05

- WH1710, 72

- B RH Processing, and WP 05

- WH1725, RH Waste Dow n loading a n d E m placement. Sat

7 Are RH containers appropr i ately

tracked?

Where is the infor m ation?

-- In the WDS, what report

-- During the receipt/transfer

process whe r e is it record ed ?

-- In the underground? Yes. Appropriate information is fo u nd i n the WDS

Canister Data Report, and on the underground facili t y

map m aintai n ed by the W a ste Handling Engineers in

the undergr ou nd. Sa t

8 Content of R H canisters

-- pick 1 to 3 canisters See It e m 3 a b ove. The Canister Data R eport was

generated and reviewed for each canis t er. Sat

9 Volume and mass and/or

concentration of i m

portant waste

c o m ponents and radi o nucl i des

(RH and CH)?

Are they within statutory a nd

regulato r y l i mits? Detailed description of nu c lide infor m ation is incl u d ed

in the Waste Container D a ta Reports and Canister

Data Reports generated.

Yes. Sat

10 Are RH bor e holes closed

proper l y?

(Note: also s e e #9 for tracking of

RH in the U/G) Recently e m p laced borehole plugs, and plugs prepared

for e m plac e ment, were observed by inspectors in the

underground to be in accordance with WP 05

- WH1725, RH Waste Downloading and E m placement. Sat

11 Is a photogr a phic record made of

the RH canister nu m

ber during

e m placement and retained in the

pe r m anent r e cord? No. The canister ID n u m b er is verified by two

operators during cask transfer, via closed

- circuit

television in accordance w ith procedure 05

- WH1710,

72

- B RH Processing, Sect i on 8.24. Tapes are

mainta in ed for one year, and WP

05

- WH17 1 0 Att. 1, RH Waste Processing Data Sheet,

then beco m e s the perman en t record. E P A finds this t o

be adequate. Sat

Question: Procedure s23

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. Sat24

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 Sat25

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 o perating 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.

W P 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. Sat

Question: Records/WDS26

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 r eport 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