### 1 DOCKET NO: A-98-49

Item: II-B3-116



## 2011 - Subpart A Inspection Report

EPA INSPECTION No. EPA-WIPP-5.11-10a

OF THE

WASTE ISOLATION PILOT PLANT May 10 – May 12, 2011

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

August 2011

### 2

### 3 Table of Contents

1.0 Executive Summary ......................................................................................................... ..........1

2.0 Inspection Scope .......................................................................................................... ..............1

3.0 Inspection Team, Observer s, and Participants ...........................................................................2

4.0 Performance of the Inspection ............................................................................................. ......2

5.0 Summary of Findings ....................................................................................................... ..........6

Attachments

Attachment A Inspection Plan and Checklist

Attachment B Documents Reviewed

1.0 Executive Summary

The U.S. Environmental Protection Agency (EPA) conducted an annua l inspection of the Department of Energy (DOE) Waste Isolation P ilot Plant (WIPP) May 10 to 12, 2011 as part of its continued oversight program. This inspec tion was conducted under the authority of 40 CFR 191, Subpart A. The purpose of this inspection was to verify that DOE was in continued compliance with the dose release sta ndard found at 40 CFR 191.03, Subpart A.

EPA reviewed DOE’s ability to monitor radi oactive releases to the public due to normal waste disposal operations and any unplanned or accidental releases that might occur during disposal operations. EPA reexamined DOE’s c ontinued moisture problems and salt loading at the Station A sampling location in the air exha ust shaft. EPA inspectors examined WIPP’s

emission control devices and methods used to estim ate radiation doses to the public. In addition, EPA inspected radiation sample locations and eq uipment, sample processing, and reviewed the computational methods used to estimate dose. EPA observed filter changes, probe pulls, and probe replacement at Station A.

EPA found that DOE continued to improve its air monitoring program during the past year. EPA verified that DOE continues to in crease probe cleaning frequency to weekly as

needed and continued to work toward an understa nding of this persistent salt occlusion problems

at Station A. DOE continues to have an eff ective radiation sampling program because of the continued diligence of site staff and can calcu late both yearly and accidental dose estimates

### 4 adequately. EPA did not have any findings or concerns.

2.0 Inspection Scope

The scope of this inspection was to verify that WIPP continues to effectively capture, measure, and calculate radiation doses to members of the public during waste disposal operations. Inspection activities included an examination of monitoring and sampling equipment. This inspection was conducted under the authority of 40 CFR 191, Subpart A.

During this inspection the Agency examined the ability of DOE to produce representative samples at Station A through changes in meteorol ogical and operational conditions which impact salt loading on the sampling probes. EPA reviewed the operation of Station B, Station C, and the

RADOS CAMs used at the air exhaust of th e active waste emplacement panel in the underground. EPA also addressed the site’s ability to character ize a radiological release during an emergency, and the tracking of samples and analytical results thr ough the WIPP laboratory.

EPA had no findings or concerns during the insp ection. EPA observed that probe A-1 failed due to salt occlusion, after only a week in place. Failure due to occlusion has been a persistent problem for A-1, and because the problem has not been as significant for A-2 and A-3, EPA prefers the use of those probes whenever possible. As more mining takes pl ace in the vicinity of the exhaust shaft, EPA may sti pulate weekly probe changes if A-1 is being used as a backup.

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

The inspection team consisted of five EPA st aff. Thomas Kesters on and Julia Marple of

the State of New Mexico Environmental Department observed the inspection.

Inspection Team Member Position Affiliation

Tom Peake Inspection Lead EPA ORIA

Kathleen Economy Inspector EPA ORIA

Shankar Ghose Inspector EPA ORIA

Nick Stone Inspector EPA Region 6

Jonathan Walsh Inspector EPA ORIA

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

Participant or Observer Participant or Observer

Mike Gross Art Chavez

Jacqueline Davis Larry Madl

Mansour Akbarzadeh Dave Speed

Jennifer Hendrickson Tom Goff

Dan Ferguson David Squires

4.0 Performance of the Inspection

The inspection began on Tuesday, May 10, 2011, w ith an opening meeting that included presentations on changes in air monitoring and WI PP laboratory activities. Site staff discussed changes in the program since the last EPA inspec tion in July 2010. These presentations included the following updates and changes to the program:

- PM 364001, revised in 2010 to stipulate more freque nt probe pulls at Station A, was followed. With a maximum probe pull interv al of two weeks, th ere were no failures of the primary probe during the past year. As noted previously, skid A- 1 has failed while it was in use as the backup

skid.

- A two-week probe pull interval for Station A skids A-2 and A- 3 did not result in a negative impact on probe occlusion.

- Heavy mining during WIPP’s maintenance outage , particularly in the E-400 exhaust drift,

### 6 impacted the Station A skids, requiring increased maintenance.

- Station C was upgraded beginning in January 2011. Flow control and backup power were upgraded, however, parts were selected so that th e isokinetic sampler continues to adhere to the ANSI N13.1-1969 standard to which it was designed.

- Underground RADOS continuous air monitors (CAMs) continue to function without filter cartridge jamming issues.

- Work on planned remote electronic access to underground RADOS CAMs has been delayed because planned system did not meet computer security requirements.

- Emergency Consequence Assessment procedure 12-ER4916, Rev. 16 has been updated, simplifying the procedure and allo wing many inputs to be made to the Hotspot code upon arrival in the EOC, before specific informati on about a given event is available.

- Study by Mike Gross, “Representative of Samp les by Shrouded Probes in the Exhaust Shaft at the WIPP”, examining the current ability of Stati on A to collect representative samples, remains

in final draft form.

The EPA inspection team reviewed procedur es, interviewed site staff, and observed activities such as filter and pr obe changes to verify the effec tive implementation of procedures relevant to Subpart A. These activities are described in detail below.

4.1 Overall Inspection Activities

The inspection team observed shrouded probe pulls and sample filter changes and at Station A, examined the weekly shrouded pr obe changes, reviewed the underground RADOS CAMs, walked through an emergency response scen ario with consequence assessment staff, and examined procedures guiding the processing of samples at the WIPP radi ochemistry laboratory.

4.2 Stations A, B, and C

Station A, which samples unfiltered air exhaus ted from the WIPP underground, has been a focus of EPA in several past inspections, due to the te ndency of salt to occlude the sampling probes, with the potential to render aerosol samples unrepre sentative. This has be en a particular problem for Skid A-1, which is nearest to the influx of water to the exhaust shaft. On May 10, the inspection team observed the routine probe pulls a nd filter changes at Station A. Because Skid A-2 was down for maintenance of its sample trans port line, Skid A-3 was the sampler of record, and Skid A-1 was collecting back-up samples. As mentioned above, despite having been in place only one week, probe A-1 failed due to exce ssive salt occlusion. Each fixed air sampler (FAS) was calibrated and flow rate s were appropriate. The inspect ion team visited Station B and the newly-refurbished Station C to verify calibration dates an d flow rates.

### 7 4.2 Consequence Analysis

On the afternoon of May 10, EPA inspectors met with Consequence Assessment staff in the Emergency Operations Center. EPA requested that a consequence assessment drill be conducted for a ten-drum overpack (TDOP) of waste falling down the waste-hand ling shaft. Site staff used current meteorological data and procedure WP 12-ER4916, Rev. 16 to perform the dose calculation first using HOTSPOT (JPW- 20110510-03) and then NARAC (JPW-20110510-04, JPW-20110510-05.)

4.3 Underground Sampling

During the underground tour on May 11, inspecto rs observed the continuous air monitors (CAMs) placed at the exha ust of Panel 6 (the active waste pane l) and at Station D, at the bottom of the exhaust shaft. Each CAM was operating with air flow and pressure differentials within the acceptable range. Station D’s calibration sticker was valid until 4/7/2011, however, the site was able to produce documentation showing that the CAM had been recalibrated (JPW-20110511- 06), even though the sticke r had not been changed.

4.4 WIPP Laboratory

EPA also toured the WIPP laboratory, which s upports annual National Emissions Standards for Hazardous Air Pollutants (NESHAP) reporting a nd emergency response activities at WIPP. Inspectors toured the laboratory it self and were given a presentati on of the laboratory’s analytical services. The laboratory quality assurance manager presented the inspection team with a data package dated April 20, 2011 and a monthly NE SHAP report for February, 2011. Inspectors verified that the proper QA and ch ain-of-custody forms had been us ed; that signat ures were in place for data entry, review, and finalization; an d that sample tracking logs were adequate. Specifically, samples were collected us ing forms found in WP 12-HP3500, Rev. 18, and laboratory QA was carried out using the forms and procedures found in WP 12-RL3002, Rev. 8.

5.0 Summary of Findings

During the inspection EPA examined DOE’s ac tivities over the past year. DOE and site staff continues to be aggressive monitoring Station A probe conditions. EPA agrees that biweekly probe changes are appropriate during the summer and when skids A-2 and A-3 are used as the skid of record. As indicated during the last inspection report, EPA feels that the draft report prepared by Mike Gross (DOE/WIPP-10-3450) provides a valuable analysis DOE’s to collect representative samples under current conditi ons. EPA recommends that this report be

finalized.

The inspection activities served to verify that DOE is correctly implementing procedures which allow it to accurately monitor and calculate pos sible radiation doses to members of the public

### 8 due to WIPP site operation. The inspection ch ecklist included as Att achment A specifically documents DOE’s compliance with each reporting expectation set forth in EPA’s WIPP Subpart A Guidance (402-R-97-001). Based on the inspecti on activities documented in this report, EPA concludes that DOE continues to adequately implement a radiological monitoring and sampling program for WIPP disposal operations in wh ich it collects representative samples and appropriately performs calculations to estimate po tential releases to the public. The results of this program, documented in the Annual Pe riodic Confirmatory Measurement Compliance Report for Calendar Year 2010 (RES 11-579) show that “the effective dose equivalent (EDE) value to the maximally exposed individual resu lting from normal operations conducted at this facility is less than 1.91x10 -05 

### millirem (mrem) per year.” Thus, DOE remains compliant with the Subpart A dose limits of 25 millirem to the whole body and 75 millirem to any other critical organ set forth in 40 CFR 191.03(b). EPA reviewed DOE’s calculations to verify that they are accurate (see Attachment A, Subpart A Checklist, for more detail). EPA does not have any findings or concerns.

### 9 Attachment A: Inspection Plan and Checklist



## WIPP Inspection Plan - 40 CFR 191, Subpart A for the year 2011
Purpose : EPA will verify that the Department of Ener gy (DOE) has accurately monitored and calculated possible radiation doses to members of the public , due either to normal operations or to any accidental releases that may have occurred during the last reporting period. This inspection is conducted under the authority of 40 CFR 191, Subpart A. This inspection is part of EPA’s continued oversight to ensure that WIPP can, during the operational phase of management and storage of radioactive waste, comply w ith the limits expressed in 40 CFR 191.03.

Scope : The scope of this inspection includes all activit ies performed by DOE at WIPP to measure and calculate any actual or potential radiation dose to members of the public during management and storage of radioactive waste, sp ecifically during the past year of site operation. Inspection

activities will include an examination of mon itoring procedures and sampling equipment both on and off site, and in the underground.

The purpose of this inspection is to verify and c onfirm that DOE at WIPP has complied with the “Compliance reporting” exp ectations of EPA’s GUIDAN CE FOR THE IMPLEMENTATION

OF EPA’s STANDARDS FOR MANAGEMENT AND STORAGE OF TRANSURANIC WASTE (40 CFR Part 191, Subpart A) at the WASTE ISOLATION PILOT PLANT (402-R-97- 001), Section 4.2, Page 15.

Focal Areas for this Years Inspection:

 What changes have taken place in air sa mpling since last year’s inspection?

 What potential changes to air sampling would result from the development of a new experimental area?

 During past years a number of potential ch anges were discussed to evaluate and

address salt occlusion on Sta tion A probes. What is the status of these activities?

 With continued moisture in the exhaus t shaft air flow, what have been the conditions of the sample filters? Have the filters had salt buildup or samples washed off as in the past?

 Verify that the underground CAMs operate as expected.

 How are composite samples handled and processed, measurement accuracy, and implications of laborat ory standards used?

 Provide a presentation of the process and procedures used to calculate off-normal potential release during opera tions. Describe the proce ss used to respond to offnormal situations from start to finish.

 Bottom-line: If required, how would DOE prove to independent examiners that samples taken at Station A are representative samples?

Location : This inspection will be held at the WIPP f acility located twenty-six miles south east

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

Duration : The EPA expects to complete its inspection in three days. Each day will begin with an opening meeting at 8:00 a.m. and end be fore 5:00 p.m. with a closeout session.

Date : May 10-12, 2011.

Information Requested: Provide documentation and proc edures related to Subpart A compliance activities as in past years. Before the inspection, provide info rmation that describes how measurements are taken, and complete documentation that shows how compliance calculations are performed with an explanation of all input parame ters and their derivation. As soon as it becomes available, please provide to EPA the 2010 Annual Safety Analysis Report.

### 11 # CHECKLIST QUESTION May 2011 40 CFR 191.03 Subpart A

Sat. = Satisfactory NA = Not Applicable

40 CFR 191.03 Compliance Standard EPA Citation Comment (Object ive Evidence) Result

Does DOE “...provide reasonable assurance that the combined annual dose equivalent to any member of the public in the general environment resulting from discharges of

radioactive material and direct radiation from such management and storage shall not exceed 25 millirems to the whole body and 75 millirems to any other critical organ.” 40 CFR 191.03(b) 40 CFR 191.03 Subpart A -

Environmental

Standards for Management and Storage DOE has demonstrated that they can capture, measure, and calculate releases to assure that they are and

remain below these limits

. Sat.

Scope of activities considered in determining compliance

1 Does DOE demonstrate that all activities at the WIPP up until the point of disposal are considered in determining compliance? Activities include those at “all WIPP facilities, both at above-ground locations and in the underground disposal system” and those related to “arrival or receipt of waste, inspections of containers, unloading, and

waste movement.” EPA 402-R97-001 Section 2.3, Page 4 The Annual Site Environmental Report for 2009 (DOE/WIPP 09- 2225) Execu tive Summary

documents DOE’s efforts to consider all activities that impact compliance. The Annual Periodic Confirmatory Measurement Compliance Report for Calendar Year 2010 (RES 11-579,

hereafter referred to as the annual NESHAP report) and inspection

activities confirm that all waste handling activities are considered in determining compliance. Sat.

### 12 2 Does DOE demonstrate that radiation doses to the public due to 1) actual normal operation and 2) any unplanned or accidental releases

are examined? EPA 402-R97-001 Section 2.3, Page 5 Section 3.0 of the Implementation Plan for Subpart A (DOE/WIPP 00- 3121, Rev. 3) documents how this requirement is met, both for normal operation and accidental releases.

Annual NESHAP report (RES 11- 579) demonstrates that normal operations are fully examined.

CH Waste Documented Safety Analysis (DOE/WIPP 95-2065, Rev. 10) and RH Waste DSA (DOE/WIPP 06-3174, Rev. 0) documents DOE’s review of potential accidents at WIPP. Procedure Emergency Radiological Control Response (WP 12-HP4000, Rev. 6) and Consequence Assessment Dose Projection (WP 12-ER4916, Rev 16) document radiological emergency response activities, including an initial assessment of possible dose to the public. Sat.

Media considered in determining compliance

3 Does DOE demonstrate that the air pathway is the credible release pathway? EPA 402-R97-001 Section 2.4, Page 5 Section 2.1 of the Implementation Plan for Subpart A describes the process by which the air pathway was

established as the credible release pathway, and the use of environmental monitoring of other exposure pathways to confirm thatthis remains the case.(DOE/WIPP00-3121, Rev. 3, p.7) Sat.

4 Does DOE demonstrate that other exposure

mechanisms from an air release could include inhalation of contaminated air, immersion in a plume of radioactive particles, ingestion of soil on which contaminated particles have been deposited, swimming in ponds in which radionuclides have been deposited are

considered? EPA 402-R97-001 Section 2.4, Page 5 Sections 2.1 and 3.5 of the Implementation Plan for Subpart A documents methods for measuring these potential exposure pathways (DOE/WIPP 00-3121, Rev. 3).

Section 4.8.4 of the ASER documents

the consideration of dose from these pathways (DOE/WIPP-10-2225). Annual NESHAP report (RES 11- 579) confirms that these exposure

mechanisms are in cluded in dose

calculations. Sat.

### 13 5 Is DOE monitoring the expected air exhaust pathway and performing environmental monitoring of other release points and exposure pathways to confirm air exhaust as the only release pathway? EPA 402-R97-001 Section 2.4, Page 5 and page 6. Yes. Section 2.1 of the Implementation Plan for Subpart A explains DOE’s plan to fulfill this requirement(DOE/WIPP-00-3121, Rev. 3). Annual Site Environmental Report Chapter 4 demonstrates that DOE implements groundwatersurveillance, biota sampling and offsite air monitoring programs (DOE/WIPP-10-2225). Sat.

Boundary of compliance

6 Does DOE demonstrate compliance at the “exclusive use area” boundary? If not, does DOE justify changing this boundary? EPA 402-R97-001 Section 2.5, Page 6.

EPA 402-R97-001 Section 2.5, Page 7 Section 3.1 of DOE/WIPP-00-3121

Rev. 3 states that the “Exclusive Use Area” will be used as the boundary for 40 CFR 191 Subpart A compliance. Sat.

Location of maximally exposed individual

7 Does DOE examine radiation doses to individuals at any offsite point where there is a residence, school, business, or office? (Such as grazing, mining, or oil drilling in the vicinity.) “The location of the maximally exposed

individual is the location where an actual

individual lives or works who receives the

maximum annual radiation dose from the

source.” EPA 402-R97-001 Section 2.6.1, Page 8 For Subpart A, DOE assumes that the member of the public resides, “... year-round at the fence line in the northwest sector” (DOE/WIPP-10- 2225, Section 4.8.4.3). Section 1.3.2

of the ASER demonstrates that DOE considers doses at appropriate offsite points, such as Smith Ranch located 7.5 km away in the WNW sector (DOE/WIPP 09-2225, p. 36).

The Annual Periodic Confirmatory Measurement Compliance Report for

the DOE WIPP for Calendar Year 2010 (RES 11-579), or “2010 NESHAP Report,” identifies Smith

Ranch as the location of the maximally exposed individual. The nearest farms, dairies, and beef ranching activities are also

considered. Sat.

8 Does DOE “analyze potential exposure pathways and examine demographic information and conduct field investigations to identify the location of actual individual who could be exposed via those pathways?” EPA 402-R97-001 Section 2.6.1, Page 8 Yes. See checklist Item 7. Sat.

### 14 9 Does DOE “conduct separate analyses of potential dose received from each exposure pathway?”

Then does DOE “assume that a member of the public resides at the single geographic point

on the surface where the maximum dose

would be received?” EPA 402-R97-001 Section 2.6.1, Page 8 Yes. See checklist Item 7. Sat.

Personal parameters EPA Citation Comments (Objective Evidence) Result

10 Does DOE assume that the individual exhibits personal characteristics of the “reference man” when evaluating radiation dose to the maximally exposed individual? EPA 402-R97-001 Section 2.6.2, Page 8 Section 3.2 of the Implementation Plan for Subpart A describes the “reference man” parameters as described in the CAP88-PC computer code (DOE/WIPP 00-3121, Rev. 3). These parameters are confirmed (on p. 16) of the CAP-88 output file included in the 2010 NESHAP report (RES 11-579). Sat.

Calculation of dose - Modeling –

Parameters

11 Does DOE provide both whole body radiation dose and critical organ radiation dose for the maximally exposed individual (or a hypothetical individual conservatively located at a point of higher exposure)? EPA 402-R97-001 Section 2.7.1, Page 8 Yes. The effective dose equivalent and table of organ dose equivalents is

included in the 2010 annualNESHAP report (RES 11-579, CAP88 output file, p.2) Sat.

12 Does DOE calculate radiation doses including all release points and reflecting evaluation of all exposure pathways? EPA 402-R97-001 Section 2.7.1, Page 8 Section 2.1 of DOE/WIPP-00-3121, Rev. 3 states that the air pathway is the most credible, but that other exposure pathways are monitored to confirm the air pa thway. Annual NESHAP report (RES 11-579) demonstrates that all release points

are evaluated. Sat.

13 Does DOE use computer modeling to calculate radiation doses for compliance with the Subpart A standard? EPA 402-R97-001 Section 2.7.2, Page 9 Section 3.2 of DOE/WIPP-00-3121, Rev. 3 states that computer models

will be used to calculate radiation doses during both routine operation

and accidental releases. Sat

14 Does DOE use CAP88-PC to perform dose

calculations? EPA 402-R97-001 Section 2.7.2, Page 9 CAP88-PC is used for dose calculations for routine operations (DOE/WIPP-00-3121 Rev 3, Section 3.2). Annual NESHAP report demonstrates that DOE is using

CAP88-PC. Sat.

### 15 15 Does DOE use an alternate model for calculating radiation doses? If so, does DOE justify such usage? EPA 402-R97-001 Section 2.7.2, Page 10 DOE uses an atmospheric dispersion code (HOTSPOT) to estimate potential radiation due to accidental releases (DOE/WIPP-00-3121 Rev 3, Section 3.2). WP 12-ER4916 Rev.

16 states that HOTSPOT is used for

accidental release calculations. During the inspection, EPA requested an example dose projection using HOTSPOT (JPW-20110510-02, -03).

DOE has demonstrated that

HOTSPOT is a reasonable choice for emergency dose calculations. Sat.

16 Does DOE adequately support exposure parameters used in dose calculations? EPA 402-R97-001 Section 2.7.3, Page 10 Annual NESHAP report (RES 11- 579) includes CAP-88 output file, demonstrating that DOE is using appropriate parameters in dose

calculations. Also see checklist items

7-10. Sat.

Calculation of dose - Modeling -

Parameters EPA Citation Comments (Objective Evidence) Result

17 Does DOE document that “conservative simplifying assumptions” are used in the

radiation dose calculations? EPA 402-R97-001 Section 2.7.3, Page 10 DOE uses conservative assumptions

to estimate worst-case dose to a maximally-exposed offsite individual (DOE/WIPP 00-3121, Rev. 3, Section 3.2). Sat.

### 16 18 Are DOE’s exposure parameters as conservative as the following?

For a maximally exposed individual located at a residence, assumed continuous exposure (24 hours per day).

For a maximally exposed individual located at a business, office, or school, assume exposure of 8 hours per day.

Assume individuals consume 2 liters per day of drinking water from an underground source of drinking water.

Assume inhalation rate for air to be 9x10 5

cm 3 /hr.

Assume ingestion rate of meat to be 85 kg/yr.

Assume ingestion rate of leafy vegetables to be 18 kg/yr.

Assume ingestion of milk to be 112 liter/yr.

Assume ingestion rate of produce to be 176 kg/yr EPA 402-R97-001 Section 2.7.3, Page 10 DOE uses these exact values as exposure parameters (DOE/WIPP 00- 3121, Rev. 3, Section 3.2). The Annual NESHAP report CAP-88 output file (p.16) demonstrates that DOE is using these parameters in dose calculations (RES 11-579). Sat.

Emissions and Environmental Monitoring -

Air EPA Citation Comments (Objective Evidence) Result

19 Does DOE demonstrate that effluent flow rate measurements are made using Reference Method 2 of Appendix A to 40 CFR Part 60 to determine velocity and volumetric flow rate for stacks and large vents? EPA 402-R97-001 Section 3.1, Page 11, (1(i)) Stations A and B use alternate methods approved by the Administrator, per Section 3.3(3) of this rule (Nichols 1994). See checklist items 25, 27.

Station C sampling was designed based on ANSI N.12-1969, Guide to Sampling Airborne Radioactive

Materials in Nuclear Facilities from which Method 2 was derived (WP 12-RC.01, Rev. 9).

DOE/WIPP 89-028, Section 1.3 confirms that “guidance was taken from . . . the CFR Title 40, Part 60, Appendix A, Reference Methods” and describes testing to establish the velocity profile for Station C. Sat.

### 17 20 Does DOE demonstrate that effluent flow rate measurements are made using Reference Method 2a of Appendix A to 40 CFR 60 to measure flow rates through pipes and small

vents? EPA 402-R97-001 Section 3.1, Page 11, (1(ii)) Not applicable at WIPP. Duct

diameter associated with WIPP exhaust point exceeds the 40 CFR 60 requirements. NA

21 Does DOE demonstrate that the frequency of flow rate measurements depend on the variability of the effluent flow rate?

Note: For variable flow rates, continuous or frequent flow rate measurements are expected to be made. For relatively constant flow rates, only periodic measurements are expected. EPA 402-R97-001 Section 3.1, Page 11, (1(iii)) DOE has implemented continuous air monitoring at WIPP, and does not need to consider this requirement. (DOE/WIPP-00-3121, Rev. 3, Section 3.3, 3.3.1) NA

22 Does DOE demonstrate that radionuclides to be directly monitored or extracted, collected and measured using Reference Method 1 of Appendix A to 40 CFR Part 60 for selected monitoring or sampling sites? EPA 402-R97-001 Section 3.1, Page 11, (2(i)) Stations A and B use alternate methods approved by the Administrator, per Section 3.3(3) of this rule (Nichols 1994). See checklist items 25, 27.

Station C sampling was designed based on ANSI N.12-1969, Guide to Sampling Airborne Radioactive

Materials in Nuclear Facilities from which Method 2 was derived (WP 12-RC.01, Rev. 9).

DOE/WIPP 89-028, Section 1.3 confirms that “guidance was taken from . . . the CFR Title 40, Part 60, Appendix A, Reference Methods.” Sat.

Emissions and Environmental Monitoring -

Air EPA Citation Comments (Objective Evidence) Result

### 18 23a Does DOE demonstrate that the effluent stream is either “directly monitored continuously with an in-line detector capable of distinguishing relevant radionuclides,” or alternately “continuousl y sampled such that analysis of filters or other collectors will provide an accurate estimate of emissions from a known flow rate during a fixed sampling time?” EPA 402-R97-001 Section 3.1, Page 11, (2(ii)) DOE implemented the latter sampling option, and continually collects samples and flow rate data to demonstrate compliance with 40 CFR 191 Subpart A. All sample filters are screened to determine that alpha and beta activity fall below set action levels, and are then submitted for analysis. As described in Section 3.3.3 of the Implementation Plan for Subpart A, DOE then uses periodic confirmatory measurements to demonstrate compliance with dose

standards. Sections 3.5 and 3.3.5

document relevant radionuclides at WIPP. (DOE/WIPP 00-3121, Rev. 3) NA

23b Does DOE demonstrat e that representative samples of the effluent stream are withdrawn from the sampling site? “...The need for continuous sampling is applicable to batch processes when the unit is in operation. Periodic sampling (grab samples) may be used in lieu of continuous sampling only with EPA’s prior approval. Such approval may be granted in cases where continuous sampling is not practical and radionuclide emission rates are relatively constant. In such cases, EPA expects grab samples to be collected with sufficient frequency so as to provide a representative sample of the emissions.” EPA 402-R97-001 Section 3.1, Page 11, (2(ii)) As stated in checklist item 23a, DOE samples continuously. After they are found to be below screening levels, all samples found to be representative are composited for periodic measurements (typically monthly for Station A, and quarterly for Stations B and C). This process is described by DOE/WIPP 97-2238, Rev. 8. The procedure Periodic Confirmatory Analysis, Reporting, and Compliance Activities (WP 12-RE3004, Rev. 3) describes the criteria for confirming that a filter sample is representative, and documents how to report and handle a sample which does not meet these requirements. Sat.

24 Does DOE demonstrate that radionuclides are collected and measured using procedures based on the principles of measurement described in Appendix B, Method 114 of 40 CFR 61? If not, does DOE demonstrate that the Administrator has approved the method

used? EPA 402-R97-001 Section 3.1, Page 12, (2(iii)) Attachment 1 to the QAPP for Sampling Emissions (WP 12-RC.01, Rev. 9) documents both the requirements of Method 114, and

where WIPP documentation reflects these principles. Sat

### 19 25 If DOE is using the “Shrouded Probe”, does

DOE demonstrate that this alternative method is being used according to the guidance provide in “An Explanation of Particle Sampling in a Moving Gas Stream Within a Duct Using an Unshrouded and Shrouded

Probe”? EPA 402-R97-001 Section 3.1, Page 12, (2(iii)(a)) An Assessment of the WIPP Shrouded Probe Against EPA Approval Criteria for Use of Single Point Sampling with the Shrouded Probe HA:98:0100 (Included in August 2000 Inspection Report, A98-49, II-B3-12, EPA’s Approval letter (Nichols 1994) documents

DOE’s evaluation of the Shrouded Probe and its compliance with the EPA criteria. Single Point Representative Sampling with Shrouded Probes (LA-12612-MS) documents how the shrouded probe was qualified for use at WIPP. Sat.

Emissions and Environmental Monitoring -

Air EPA Citation Comments (Objective Evidence) Result

26 Does DOE’s quality assurance program meet the performance requirements described in Appendix B, Method 114 of 40 CFR Part 61? EPA 402-R97-001

Section 3.1, Page 12, (2(iv)) QAPP for Sampling Emissions (WP 12-RC.01, Rev. 9) Section 1.0 documents DOE quality assurance requirements. These meet the requirements of 40 CFR 61. See

Checklist Item 24. Sat.

27 If it is impractical to measure the effluent flow rate in accordance with the method(s) in Section 3.1(1) or to monitor or sample extraction according to methods in Section 3.1(2) has DOE demonstrated that the use of

alternative effluent flow rate measurement or site selection and sample extraction are appropriate and that the alternate method are used provided the following:

(i) DOE shows that methods in Section 3.1(1) or (2) are impractical; (ii) DOE shows the alte rnative procedure will not significantly underestimate the emissions; (iii) DOE shows the alternative procedure is fully documented; and (iv) DOE has received prior approval from

EPA. EPA 402-R97-001

Section 3.1(3)(i) to (3)(iv), Page

12 At Stations A and B, DOE uses alternate methods per Section 3.3(3)of the Subpart A Guidance (402-R97-001). See checklist items 25 and

27.

Single Point Representative Sampling with Shrouded Probes (LA-12612- MS) documents how the shrouded probe was technically qualified for use at WIPP. EPA’s Approval letter (Nichols 1994) documents DOE’s compliance with these criteria, and EPA’s approval. NA.

### 20 28 Does DOE demonstrate that radionuclide

emission measurements are in conformance with the methods in Section 3.1(1) and (2) to be made at all release points which have a potential to discharge radionuclides into the air in quantities which could cause a combined annual dose equivalent in excess of 1% of the dose limit in Subpart A? EPA 402-R97-001 Section 3.1, Page 12 and

p age 13, (4(i)) DOE/WIPP 00-3121, Rev. 3., Section 3.2 documents DOE’s compliance with this requirement. All areas of a potential discharge are continuouslysampled, although even in a worstcase accident scenario, 1% of the Subpart A dose limit is not expected to be reached. This requirement is

also discussed in Sections 1.0 and 2.0 of DOE/WIPP 97-2238, Rev. 8. Sat.

29 Does DOE demonstrate that all radionuclides which could contribute greater than 10% of the combined annual dose equivalent for a release point are being measured? EPA 402-R97-001 Section 3.1, Page 13, (4(i)) Section 3.3 of the Periodic Confirmatory Measurement Protocol (DOE/WIPP 97-2238, Rev. 8) states that the selected analytes “constitute approximately 98% of the dose due to the average source term for CH

and RH wastes.” Sat.

Emissions and Environmental Monitoring -

Air EPA Citation Comments (Objective Evidence) Result

30 If DOE uses alternative procedures to determine emissions, does DOE demonstrate that they have prior EPA approval? EPA 402-R97-001 Section 3.1, Page 13, (4(i)) DOE uses the shrouded sampling probe as an alternative method. EPA has formally approved this alternative method (Nichols, 1994). NA

31 Does DOE demonstrate that for other release points which have a potential to release radionuclides into the air it has performed periodic confirmatory measurements to verify

the low emissions? EPA 402-R97-001 Section 3.1, Page 13, (4(i)) DOE has no other points with a potential to release radionuclides. CH (DOE/WIPP-95-2065,Rev. 10) and RH (DOE/WIPP-06-3174, Rev. 0) Waste Documented Safety Analysis document these

conclusions. NA

32 Does DOE demonstrate that an evaluation has been done to evaluate the potential for radionuclide emissions for a release point? EPA 402-R97-001 Section 3.1, Page 13, (4(ii)) Yes. See checklist item 28 NA

33 Does DOE demonstrate that in evaluating

whether emissions must be measured for a given release point, estimated radionuclide release rates are based on discharge of effluent stream that would result if all pollution control equipment did not exist, but the facilities operations were otherwise normal? EPA 402-R97-001 Section 3.1, Page 13, (4(ii)) Stations B and C use pollution control equipment. However, because DOE has chosen to sample continuously at these locations, this requirement is not applicable. Sat.

Environmental Measurements EPA Citation Comments (Objective Evidence) Result

### 21 34 Does DOE demonstrate that environmental

measurements of concentrations of radionuclides in air at the critical receptor

locations are used as an alternative to air dispersion calculations in demonstrating compliance with the standard? EPA 402-R97-001 Section 3.1, Page 13, (5) DOE does not use environmental monitoring as an alternative to comply with 40 CFR 191.03 Subpart A. DOE samples at release points. NA

35 Does DOE demonstrate that air at the point of measurement is continuously sampled for

collection of radionuclides if environmental

measurements are used? EPA 402-R97-001 Section 3.1, Page 13, (5(i)) Section 3.1(5) of EPA 402-R-97-001 is not applicable. See checklist item

34. NA

36 Does DOE demonstrate that the environmental measurement program is appropriately designed to collect and measure specifically those radionuclides which are major

contributors to the annual radiation dose from the facility? EPA 402-R97-001 Section 3.1, Page 13, (5(ii)) Section 3.1(5) of EPA 402-R-97-001 is not applicable. See checklist item

34. NA

37 Does DOE demonstrate that radionuclide

concentrations which would cause an annual dose equivalent of 10% of the standard are readily detectable and distinguishable from background? EPA 402-R97-001 Section 3.1, Page 13, (5(iii)) Section 3.1(5) of EPA 402-R-97-001 is not applicable. See checklist item

34. NA

38 Does DOE demonstrate that a quality assurance program that meets the performance requirements described in 40 CFR Part 61, Appendix B, Method 114 is conducted for

environmental measurements? EPA 402-R97-001 Section 3.1, Page 13, (5(iv)) Section 3.1(5) of EPA 402-R-97- 001 is not applicable. See checklist

item 34. NA

39 Does DOE demonstrate that EPA has granted prior approval for the use of environmental measurements to demonstrate compliance with

the standard? EPA 402-R97-001 Section 3.1, Page 13, (5(v)) DOE has not requested approval to

use environmental measurements. NA

Emissions and Environmental Monitoring -

Other Media

### 22 40 Does DOE demonstrate that environmental monitoring of other release points or critical receptor locations to confirm air exhaust as the only release pathway? EPA 402-R97-001 Section 3.2, Page 14. Implementation Plan for Subpart A, Section 2.1 states; “However, to confirm that the air pathway is the only credible pathway for radiological releases, WIPP implements a radiological ground water surveillance program, biota sampling program and off-site radiological air monitoring program” (DOE/WIPP00-3121, Rev. 3). ASER Chapter 4 demonstrates that DOE’s environmental program monitors other release points and critical receptor locations(DOE-WIPP 10- 2225). Sat.

Compliance Reporting EPA Citation Comments (Objective Evidence) Result

41 Does DOE demonstrat e compliance with the Subpart A standard by showing that the annual radiation dose to any member of the public in the general environment falls below the regulatory limits? EPA 402-R97-001 Section 4.2, Page 15. The Annual NESHAP report demonstrates that DOE reports results yearly, and that those results fall below regulatory limits. For calendar year 2010, the calculated effective dose equivalent to the maximally exposed individual of the public was less than 1.91x10 -5 mrem (RES 11-579). Sat.

42 Does DOE report results of monitoring and the dose calculations for each reporting period? EPA 402-R97-001 Section 4.2, Page 15 Section 5.0 of DOE/WIPP 00-3121 documents that DOE’s plans to report

annual results. Th e Annual NESHAP Report demonstrates that DOE reports results of monitoring and dose results yearly – see checklist item 41. Sat.

43 Does DOE demonstrate that monitoring is performed each calendar year of facility operation, and that radiation doses are calculated after the end of each year? EPA 402-R97-001 Section 4.2, Page 15 Yes. See checklist item 42. Sat.

Notification of construction or

modification.

44 Does DOE demonstrate that they have provided the EPA written notification of any planned construction or modification to the WIPP facility, prior to commencing any such activity, if it results in an increase in the rate of emissions of radionuclides during operation? EPA 402-R97-001 Section 4.3, Page 16. The Annual NESHAP Report includes a description of construction and modifications during each reporting period. None requiring advanced notice took place during 2010 (RES 11-579). Sat.

### 23 45 Does DOE demonstrate that advanced

notification was not needed for construction

and modification if the radiation dose caused by all the emissions from the new construction or modification is less than 1% of the Subpart

A dose limits? EPA 402-R97-001 Section 4.3, Page 16 and page 17. Yes, this is accomplished by the Annual NESHAP Report. See

checklist item 44. Sat.

Record Keeping

46 Does DOE demonstrate documentation is sufficient to allow the Agency to verify the

correctness of the determination made concerning the WIPP’s compliance with Subpart A? EPA 402-R97-001 Section 4.4, Page 17. Through its various documents, Subpart A implementation plan, its Annual NESHAP Report, and many procedures that support Subpart A activities, DOE demonstrates that

documentation is sufficient to allow EPA to verify compliance with Subpart A. Sat.

### 24 Attachment B

Table of Documents ReviewedDocuments Reviewed and Copies ReceivedDuring Inspection191.03 Subpart A Inspection May 2011CitationDocument TitleSubject MatterSourceLegal and Technical Reference DocumentsEPA 402-R-97-001 Guidance For The Implementation of EPA's Standards ForManagement And Storage of Transuranic Waste (40 CFRPart 191, Subpart A) at the Waste Isolation Pilot Plant.EPA 402-R-97-001,January1997"WIPP Subpart A Guidance," EPAA-92-56, II-C-2 Memorandum of understanding between EPA and DOE,September 29, 1994Agreement states that although not required, DOE willimplement NESHAPs Subpart H regulations at the WIPPsite until closure.DOE/WIPPDOE/WIPP 93-043 Effects of Salt Loading and Flow Blockage on the WIPPShrouded Probe, by Chandra, Ortiz, McFarland, August1993,DOE/WIPP 93-043Report discusses the impact of salt loading on shroudedprobe performance.DOE/WIPPDOE/WIPP 89-027 Evaluation Of The Station B Effluent Monitoring SystemIn The Underground Exhaust Ventilation System At TheWIPP,Sept 1990,DOE/WIPP 89-027Documents testing at WIPP to evaluate the ability ofStation B to collect representative samples.DOE/WIPPEEG-60 The Influence of Salt Aerosol On Alpha RadiationDetection By WIPP Continuous Air Monitors, by Bartlettand Walker, Jan 1996, EEG-60, DOE/AL/58309-60Reports impact of salt deposits on monitor efficiency. DOE/WIPPDOE/WIPP 89-026 Evaluation Of The Station A Effluent Monitoring SystemIn The Underground Exhaust Ventilation System At TheWIPP,DOE/WIPP 89-026,Sept 1990Documents testing at WIPP to evaluate the ability ofStation A to collect representative samples.DOE/WIPPRodgers et al., 1994 Single Point Aerosol Sampling: Evaluation of Mixing andProbe Performance In A Nuclear Stack, by Rodgers,Fairchild, Wood, Ortiz, Muyshondt, McFarland, July 1994Compares performance of ANSI isokinetic with shroudedprobes at DOE faculties.DOE/WIPPPNL-10816 Generic Air Sampler Probe Test, by Glissmeyer andLigotke, Nov 1995, PNL-10816Test of isokinetic and shrouded probes at Hanford. Testsshow that shrouded probes deliver samples withsignificantlylessparticle-size bias.DOE/WIPPPNL-10148 Functional Requirements Document For MeasuringEmissions Of Airborne Radioactive Materials, byGlissmeyer, Alvarez, Hoover, McFarland, Newton,Rodgers,Nov 1994,PNL-10148States general functional requirements for system andprocedures for measuring emissions.DOE/WIPPDocuments Reviewed and Copies ReceivedDuring Inspection191.03 Subpart A Inspection May 2011CitationDocument TitleSubject MatterSourcePNL-SA-25532 Changing Methodology For Measuring AirborneRadioactivity Discharges From Nuclear Facilities, byGlissmeyer and Ligotke,May1995,PNL-SA-25532Tests show single-point sampling (shrouded) probes aresuperior to ANSI style multiple-point probes.DOE/WIPPNichols, 1994 EPA Shrouded Probe Approval. Letter from Mary Nicholsto Raymond Pelletier, dated November 21, 1994.Allows DOE to use the shrouded probe as an alternativemeasuring procedure.DOE/WIPPLA-12612-MS Single-Point Representative Sampling with ShroudedProbes by McFarland and Rodgers, LA-12612-MS, August1993Describes shrouded probe testing requirements and testperformed to qualify probe for use at WIPP.DOE OSTIDocumentwebsite.McFarland, 1993 Air Sampling With Shrouded Probes At The WIPP Site, byMcFarland,Sept 1993Paper discussing the use of the shrouded probe at WIPP.Benefits of the shroudedprobe are discussed.DOE/WIPPDOE Procedural DocumentsWP 12-2, Rev 15 WIPP ALARA Program Manual, WP 12-2, Revision 15,06/03/10Describes organization and responsibilities of ALARAcommittee and coordinator.DOE/WIPP12-RL.01, Revision 17 Radiochemistry Quality Assurance Plan, 12-RL.01,Revision 17, 04/06/11Describes the management policy and organizationalstructure, and QA requirement for radiochemical analysis.DOE/WIPPDOE/WIPP 00-3121,Revision 3Implementation Plan for 40 CFR 191, Subpart ADOE/WIPP 00-3121,Revision 3,January2010Outlines program at WIPP to show compliance with 40CFR 191,Subpart A.DOE/WIPPDOE/WIPP 09-2225 Waste Isolation Pilot Plant Annual Site EnvironmentalReport for 2009,DOE/WIPP 09-2225,September 2010Results of the environmental monitoring program, inparticular radiological measurements.DOE/WIPPDOE/WIPP 97-2238 Periodic Confirmatory Measurement Protocol for theWaste Isolation Pilot Plant, DOE/WIPP 97-2238, Revision8,August 2008Used to explain the protocol used to perform periodicconfirmatory measurements.DOE/WIPPDOE/WIPP 99-2194,Rev 5Waste Isolation Pilot Plant Environmental MonitoringPlan. DOE/WIPP 99-219, Rev 5, December 2010.DOE environmental monitoring plans at the WIPP site. Ofparticular interest: Section 4.0, Dose Calculations, and 5.0,Environmental MonitoringProgram.DOE/WIPPDOE/WIPP 99-3119,Rev 6Compliance Monitoring Implementation Plan for 40 CFR194.14(b), Assurance Requirement, DOE/WIPP 99-3119,Rev 6,05/10Outlines monitoring activities at WIPP to demonstratecompliance with 40 CFR 191 and 40 CFR 194.DOE/WIPPDOE/WIPP-06-3174Rev 0,03/06WIPP RH Waste Documented Safety Analysis, Section3.4.1.4. DOE/WIPP-06-3174 Rev 0,03/06This selection verifies that the air pathway is the onlypathwayof concern at the WIPP for RH waste.DOE/WIPP.Documents Reviewed and Copies ReceivedDuring Inspection191.03 Subpart A Inspection May 2011CitationDocument TitleSubject MatterSourceDOE/WIPP-95-2065Rev. 10,11/06WIPP CH Waste Documented Safety Analysis, Section3.4.1.4. DOE/WIPP-95-2065 Rev. 10,11/06This selection verifies that the air pathway is the onlypathwayof concern at the WIPP for CH waste.DOE/WIPP.IC041072, Rev 9 Calibration of Effluent Monitoring Skids A1, A2, A3, B1and B2 Flow Instrumentation, Maintenance Procedure,IC041072,Revision 9Instructions for calibration of FAS skids A1, A2, A3, B1and B2 flow instrumentation.DOE/WIPPIC041097, Rev 2 Calibration of Station C Flow Instrumentation,Maintenance Procedure IC041097,Revision 2Instructions for calibration of Station C flowinstrumentation.DOE/WIPPIC041098, Revision 5 U/G Exhaust Mass Flow Measurement System for Fans700A, B & C, Maintenance Procedure, IC041098, Revision5Documents calibration verification test and alignment ofU/G exhaust.DOE/WIPPIC413000, Revision 5 Station B Mass Flow Measurement System, Loop41A001W2001, Maintenance Procedure, IC413000,Revision 5Documents calibration of Station B mass flowmeasurement system.DOE/WIPPPM364001, Revision 1 Predictive Maintenance to Determine Station A Probe PullFrequency, Maintenance Procedure PM364001, Revision 1Determine recommended frequency of Station A probeinspections based on meteorological data.DOE/WIPPPM364005,Revision 10Inspection and Cleaning of Station “A” Sample ProbesBldg. 364, Maintenance Procedure, PM364005,Revision 10Documents steps to inspect and clean Station A probes.Section 8.3 notes that salt buildup "at the probe inletshould be no more than 2/3 of the area" and "blocking theshroud exhaust should be limited to no more than 1/3 ofthatarea".DOE/WIPPRES 11-579-a, -b, -c Annual Periodic Confirmatory Measurement ComplianceReport for the DOE WIPP for Calendar Year 2010,submitted 6/28/2011Annual NESHAP report. Includes cover letter, report, andCAP88-PC Version 3.0 output file. Documents annualresults.DOE/WIPPWP 12-ER4903, Rev 14 Radiological Event Response, Emergency ResponseProcedure, WP 12-ER4903, Revision 14, 7/19/10Procedure documents actions to be taken by CMRO, FSO,and Radcon if a potential or actual radioactive release takesplace.DOE/WIPPWP 12-ER4916 Consequence Assessment Dose Projection, TechnicalProcedure, Rev 16, 4/7/11Procedure for estimating the potential dose consequencefrom a release or suspected release of radioactive material,using Hotspot, NARAC, or hand calculations.Documents Reviewed and Copies ReceivedDuring Inspection191.03 Subpart A Inspection May 2011CitationDocument TitleSubject MatterSourceWP 12-ER4916 Consequence Assessment Dose Projection, TechnicalProcedure WP 12-ER4916, Revision 15, 11/16/09Documents procedure for estimating the potential doseconsequence from a release or suspected release ofradioactive material. Reviewed for consistency withRev.16DOE/WIPPWP 12-ER4916,Revision 13Consequence Assessment Dose Projection, TechnicalProcedure WP 12-ER4916, Revision 13, 06/24/09Documents procedure for estimating the potential doseconsequence from a release or suspected release ofradioactive material.DOE/WIPPWP 12-HP1305, Rev 9 Fixed Air Monitoring Equipment, Technical ProcedureWP 12-HP1305, Revision 9, 07/06/10Instructions for the operation of fixed air monitoringequipment. Attachment 2 documents flow rates and alarmsetpoints.DOE/WIPPWP 12-HP1306, Rev 8 Canberra Alpha Sentry Continuous Air Monitor, TechnicalProcedure WP 12-HP1306, Revision 8, 3/21/10Instructions for operating the Canberra continuous airmonitor equipment at waste revieving bays. Includes dailycheck sheets.DOE/WIPPWP 12-HP1307, Rev 10 Portable Instrument and Portal Monitor OperabilityChecks, Technical Procedure, WP 12-HP1307, Revision10,05/14/09Instructions for operational checks of portablecontamination instruments.DOE/WIPPWP 12-HP1308,Revision4Portable Alpha-6 Continuous Air Monitors, TechnicalProcedure WP 12-HP1308,Revision 4,3/28/11Instructions for operation of Portable Alpha-6 continuousair monitor.DOE/WIPPWP 12-HP1500Radiological Postingand Access ControlWP 12-HP3500,Revision 18Airborne Radioactivity - Technical ProcedureWP 12-HP3500, Revision 18, 05/07/10Technical procedure. Provides instructions for analyzing,reporting, and trending results of air samples. Att. 5contains Guide for Station A Filter Counting for Re-Entryinto the U/G.DOE/WIPPWP 12-HP3700, Rev 4 Radiological Event Reporting, Management ControlProcedure WP 12-HP3700,Revision 4,8/18/10Documents the first estimate of a possible release. DOE/WIPPWP 12-HP4000,Revision 6Emergency Radiological Control Responses, Emergencyand Alarm Response Procedure, WP 12-HP4000, Revision6,05/27/10Addresses radiological contamination events which requirean immediate stop work order.DOE/WIPPWP 12-RC.01, Rev 9 Quality Assurance Program Plan for Sampling Emissionsof Radionuclides to the Ambient Air at the Waste IsolationPilot Plant, WP 12-RC.01, Revision 9, 04/26/10QA program for sampling air emissions at WIPP.Contains useful background information regarding thedesign and qualification of sampling systems at Stations AD.DOE/WIPPDocuments Reviewed and Copies ReceivedDuring Inspection191.03 Subpart A Inspection May 2011CitationDocument TitleSubject MatterSourceWP 12-RE3002, Rev 3 Radiological Engineering Off-site Air Sampling -Technical Procedure WP 12-RE3002, Revision 3, 12/13/10Instructions for collecting and documenting Low-Volumefilter retrieval in response to a potential release.DOE/WIPPWP 12-RE3003,Revision 4Radiological Release of Potentially ContaminatedMaterials, Waste, and Items - Management ControlProcedure,WP 12-RE3003,Revision 4,10/27/09Instructions for evaluating materials, waste, and itemswhich are to be released from the WIPP as non-radioactivematerial.DOE/WIPPWP 12-RE3004, Rev 3 Periodic Confirmatory Sampling, Reporting, andCompliance Activities, Management Control Procedure,WP 12-RE3004,Rev 3,11/12/09This procedure provides instructions for RadiologicalEngineers of the Radiological Controls Department tofulfill the requirements of NESHAPs.DOE/WIPPWP 12-RL1001 Sample Tracking and Custody, Technical Procedure, WP12-RL1001,Revision 9,02/11/09Instructions for documenting receipt and storage ofsamples in WIPP laboratory.DOE/WIPPWP 12-RL1002, Rev 9 Alpha Spectroscopy System Operation, TechnicalProcedure, WP 12-RL1002, Revision 9, 10/05/09Direction for calibrating and operating the Canberra AlphaSpectroscopy System as interfaced with the Genie 2000.DOE/WIPPWP 12-RL1008, Rev 7 Establishing Gross Alpha and Gross Beta Self-AbsorptionCurves, Technical Procedure, WP 12-RL1008, Revision 7,11/17/09Instructions for preparing samples of known activity andknown weight to generate self-absorption curves for eachof thegasproportional counters.DOE/WIPPWP 12-RL1009, Rev 4 Gross Alpha and Gross Beta Activity in Air Filter, Soil,Water, Sludge, and Biota, Technical Procedure, WP 12-RL1009,Revision 4,10/22/07Guidance for rapidly performing a variety of screeningmatrices for both high and low activity Radionuclides.DOE/WIPPWP 12-RL1010, Rev 10 Sample Preparation, Technical Procedure, WP 12-RL1010,Revision 10,7/22/10Directions for preparing samples to determine activity ofradionuclides.DOE/WIPPWP 12-RL1011, Rev 11 Elemental Separation - Strontium 90, Technical Procedure,WP 12-RL1011,Revision 11,09/13/07Directions for performing elemental separation ofstrontium from samples.DOE/WIPPWP 12-RL1012, Rev 8 Elemental Separation - Transuranic Products, TechnicalProcedure,WP 12-RL1012,Revision 8,10/31/06Describes method for elemental separation and purificationof actinide isotopes in samples.DOE/WIPPWP 12-RL1013, Rev 7 Sample Mounting, Technical Procedure, WP 12-RL1013,Revision 7, 09/12/07Directions for electrodeposition sample mounting andneodymium fluoride coprecipitation sample mounting ofactinides in preparation for alpha spectroscopy counting.DOE/WIPPWP 12-RL1014, Rev 6 Routine Laboratory Operations, Technical Procedure, WP12-RL1014,Revision 6,11/05/08Instructions for routine laboratory operation. DOE/WIPPDocuments Reviewed and Copies ReceivedDuring Inspection191.03 Subpart A Inspection May 2011CitationDocument TitleSubject MatterSourceWP 12-RL1015, Rev 16 Canberra Alpha Analyst System Operation, TechnicalProcedure,WP 12-RL1015,Revision 16,9/09/10Directions for calibrating and operating the CanberraAlpha Analyst 32-chamber alpha spectroscopysystem.DOE/WIPPWP 12-RL1016, Rev Operation of the Oxford Series 5 Gas ProportionalCounter, Technical Procedure, WP 12-RL1016, Revision11, 8/31/10Guidance for the operation of the Oxford Series 5 GasProportional Counter. Editoial changes and instructionsfor a power outage made since 2010 inspectionDOE/WIPPWP 12-RL1200,Revision 0Plutonium-241 Analysis, Technical Procedure, WP 12-RL1200, Revision 0, 11/26/03Provides method for the analysis of Pu 241 in any matrixafter preparation of the sample in accordance with WP 12-RL1012 and WP 12-RL1015.DOE/WIPPWP 12-RL1400, Rev 9 Radiochemistry Laboratory Waste Management, TechnicalProcedure, WP 12-RL1400, Revision 9, 04/02/09Instructions for handling, management, and disposal oflaboratory waste.DOE/WIPPWP 12-RL1550,Revision 11Control of Radioactive Standards, Technical Procedure,WP 12-RL1550, Revision 11, 10/22/09Instructions for labeling, maintaining inventory, dilution ofstandards, completing standard logbook for new standardsreceived, expired standards, depleted standards, andrecertification or standards.DOE/WIPPWP 12-RL3002,Revision 8Radiochemistry Laboratory Data Validation andVerification, Technical Procedure, WP 12-RL3002,Revision 8,8/27/2010Instructions for performing radiochemistry analytical dataverification and validation by radiochemistry staff.DOE/WIPPWP 12-RL3003, Rev. 8 Data Reduction and Reporting, Technical Procedure, WP12-RL3003,Revision 8,2/7/11Instructions for processing laboratory data from the time ofsample receipt to the reportingof final results.DOE/WIPPWP 13-1, Rev 30 Washington TRU Solutions LLC Quality AssuranceProgram Description,WP 13-1,Revision 30,11/15/10Identifies Federal and industry quality standards, and setsstandards for WIPPQAprograms.DOE/WIPPWP12-5, Rev 13 WIPP Radiation Safety Manual, WP12-5, Rev 13, 05/20/10 States radiological control policy and practices, definesdosimetryterms.DOE/WIPPWP12-EM1012 Airborne Particulate Sampling, Rev 9, 06/07/07 Provides steps for environmental monitoring personnel toinstall and collect air filters and maintain records.DOE/WIPPWP12-HP2001, Rev 4 Abnormal Radiological Conditions, WP12-HP2001, Rev 4,06/24/09Instructions for radiological control technicians whenrespondingto abnormal conditions.DOE/WIPPWP12-HP3000, Rev 15 Radiological Control Administration, WP12-HP3000, Rev15,11/11/10Instructions for performing radiological control. DOE/WIPPDocuments Reviewed and Copies ReceivedDuring Inspection191.03 Subpart A Inspection May 2011CitationDocument TitleSubject MatterSourceWP12-HP3200, Rev 12 Radioactive Material Control, WP12-HP3200, Rev 12,4/04/11Instructions for controlling radioactive items DOE/WIPPWP12-HP3300, Rev 2 Radiation Exposure Control, WP12-HP3300, Rev 2,08/17/05Guidance for keeping radiation exposure ALARA. DOE/WIPPWP12-HP3400, Rev 8 Contamination Control, WP12-HP3400, Rev 8, 02/20/09 Management Control Procedure. Guidance and forms forradiological surveys and decontamination.DOE/WIPPDocuments Generated DuringInspectionJPW-20110510-01 Underground Escape Map, effective date 3/2/2011 Marked with locations of inspection activitiesDOE/WIPPJPW-20110510-02 WP 12-ER4916, Attachment 1 - Dose ProjectionSCompleted during 5/10 accidental release drillDOE/WIPPJPW-20110510-03 Hotspot Output Table, generated 5/10/2011DOE/WIPPJPW-20110510-04 NARAC Report, generated 5/10/2011DOE/WIPPJPW-20110510-05 NARAC Plot of Total Effective Dose EquivalentDOE/WIPPJPW-20110511-06 Station D1 calibration report, 3/21/2011DOE/WIPPJPW-20110511-07 Photographs and pixel counts of Station A shroud occlusion, 5/10/2011, 5 pp.DOE/WIPPJPW-20110511-08 Convergence graph S2750-W0093DOE/WIPPJPW-20110511-09 Convergence graph E300-S2180DOE/WIPPJPW-20110511-10 Extensiometer graph 51X-GE-00389, W390-S3480DOE/WIPPJPW-20110511-11 DIGILEV output file, 3pp.DOE/WIPP