1 DOCKET NO: A-98-49

Item: II-B3-116



### 2011 - Monitoring Inspection Report

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

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

October 20112 

### Contents

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

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

3.0 Inspection Team, Observer s, and Participants .......................................................................... 5

4.0 Inspection Schedule ....................................................................................................... ........... 6

4.1 Monitoring of Geomechan ical Parameters ............................................................................ 6

4.2 Monitoring of Hydrological Parameters ............................................................................... 7

Culebra Groundwater Composition ......................................................................................... 7

Changes in the Culebra Groundw ater Flow Direction ............................................................ 9

4.3 Monitoring of Waste Activity Parameters .......................................................................... 11

4.4 Monitoring of Drilling Related Parameters ......................................................................... 12

4.5 Monitoring of Subsidence Parameters ................................................................................ 12

5.0 Summary of Results ........................................................................................................ .... 13

Attachment A: Inspection Plan and Checklist ............................................................................. 14

Attachment B: Documents Reviewed ........................................................................................... 22

Tables

Table 1 Monitored Parameters

Table 2 Geomechanical Parameters and Values Measured to Confirm Them3 

### 1.0 Executive Summary

The U.S. Environmental Protection Agency (EPA) conducted an inspection of the Department of Energy’s (DOE) Waste Isolation Pilot Plant (W IPP) from May 10 to May 12, 2011 as part of EPA’s continuing WIPP oversight program. The purpose of this inspection was to verify that DOE continues to adequately monitor ten parameters listed in the Compliance Certification Application (CCA), Volume 1, Section 7.0, in particular Table 7-7 (See Table 1, EPA INSPECTION IDM2010-1). Attachment A of this in spection report contains the inspection plan and the checklist used by the EPA inspectors, a nd Attachment B lists do cuments reviewed by the

EPA.

The inspection examined the implementation of monitoring for geomechanical, hydrological, waste activity, drilling related, and subsidence parameters. EPA inspectors toured locations where measurements are taken, reviewed parame ter databases, and reviewed documents and procedures directing thes e monitoring activities.

The EPA found that DOE continues to effectiv ely implement the monitoring programs at WIPP for all areas reviewed. EPA did not have any findings or concerns. The inspectors also

confirmed that the results of DOE mon itoring programs are reported annually.



### 2.0 Scope

The EPA WIPP Compliance Crit eria (40 CFR Part 194.42(a)) require DOE to “conduct an analysis of the effects of disposal system parame ters on the containment of waste in the disposal system.” The results of these analyses were included in the 1996 Compliance Certification Application (CCA), confirmed in the most recent Compliance Recertification Application (CRA), and were used to develop pre-clos ure and post-closure monitoring requirements.

Volume 1, Section 7.0, of the CCA documents DOE’ s analysis of monitoring parameters. Table 7-7 of the CCA lists the ten parameters that DOE determined may affect the disposal system. These parameters are grouped into major categor ies and listed in Table 1. EPA accepted these ten monitoring parameters in the 1998 Certific ation Decision and confirmed them in the 2010

Recertification Decision.

Table 1. Monitored Parameters Parameter Categories Parameter

Geomechanical Creep closure

Extent of deformation

Initiation of brittle deformation Displacement of deformation features Hydrological Culebra groundwater composition Change in Culebra groundwater flow direction

Subsidence Subsidence measurements Drilling Related Drilling rate Probability of encountering a Castile brine reservoir4 Waste Activity Waste activity

This inspection was performed under the authority of 40 CFR 194.21, which authorizes EPA to verify the continued effectiveness of the para meter monitoring program at WIPP. Inspection

activities included an examination of monitori ng and sampling equipment both on and off site, and in the underground. EPA also reviewed numerous sampling procedures and measurement techniques and verified impleme ntation of an effective qual ity assurance program (see the

document list in Attachment B of this report).5 

### 3.0 Inspection Team, Observers, and Participants

The inspection team consisted of five EPA st aff listed in Table 1. Others observing the inspection were Thomas Kesterson and Julia Marp le of the State of New Mexico Environmental Department . Table 2. WIPP Inspection Team Inspection Team Member Role Affiliation Tom Peake Inspection Leader EPA ORIA Nick Stone Inspector EPA Region 6

Jonathan Walsh Inspector EPA ORIA Shankar Ghose Inspector EPA ORIA

Kathleen Economy Inspector EPA ORIA6 

### 4.0 Inspection Schedule The inspection began on Tuesday, May 10, 2011, w ith an opening meeting where site staff presented changes in the monitoring programs since the previous inspection. On May 11 the inspection continued with interviews and demonstr ations of various aspects of each parameter monitoring area. The collection of geomechanical measurements in the underground and the collection of Culebra water samples in the fi eld were both inspected on May 11th. On May 12 the EPA inspectors examined the database(s) used to store Delaware Basin parameters and the WIPP Waste Data System (WDS formally WWIS) waste computer database system. The inspection closeout meeting was held on May 12, 2011 in Carlsbad New Mexico

EPA inspectors reviewed three fundamental area s to verify continued implementation of the DOE parameter monitoring program during the pr e-closure phase: 1) written plans and procedures, 2) quality assuran ce procedures and records, and 3) results of the monitoring program in the form of raw data, intermediate re ports, and final annual reports, if appropriate. The inspection checklist in Attachment A provi des details of these inspection activities.



### 4.1 Monitoring of Geom echanical Parameters DOE committed to measure four geomechanical para meters in the CCA: creep closure, extent of deformation, initiation of brittle deformation, a nd displacement of deformation features. These parameters are monitored through convergence m onitoring, deformation monitoring, fracture mapping and stratigraphic and fr acture mapping, respectively. WIPP has four programs that supply information for these four parameters : the geomechanical m onitoring program, the geosciences program, the ground control program, and the rock mechanics program. These programs are documented in WP 07-1, WIPP Ge otechnical Engineering Program Plan. The status of geomechanical monitoring procedures , with respect to changes and revisions, is provided below.

 WP 07- EU1301, Manually Acquired Geomechanic al Instrument Data – No change

 WP 07-EU1304, Installing Convergence Reference Points – No change

 WP 07-EU1306, Installing Rock Bolt Load Cells – No change

 WP07-EU1308, Installing Wire Extensometers – No change

 WP 07-EU1001, Geologic and Fracture Mapping of Facility Horizon Drifts – Revision 3
(07/21/11)

 WP 07-EU1303, Geomechanical Instrument Da ta Processing - Re vision 4 (05/03/11)

In addition to reviewing procedures, EPA insp ectors examined monitoring and measurement techniques, manually and remotely acquired inst rument data and the storage, accuracy and consistency of the reported data in DOE WIPP Re ports. Inspection perso nnel interviewed WIPP geotechnical engineering personnel to discu ss any programmatic changes, observed manual convergence measurements and fracture mappi ng, examined data from stratigraphic mapping and remotely measured extensiometers, compared staff practices to written procedures, and

reviewed the annual WIPP Geotechnical An alysis Report for July 2009 to June 2010 (DOE/WIPP 11-3177, March 2011).7 EPA met with staff from the WIPP Geotechni cal Engineering Program and asked about programmatic changes, observed manual data collection processes and examined the Geomechanical Instrument Data Processing technical procedure (WP 07-EU1303, Rev 4). While in the underground on the morning of May 11, WIPP geomechanical staff manually measured the convergence in Panel 6 at S2750- W93. The inspector examined the process

followed and found it to be in c oncurrence with the process do cumented in WP 07-EU1303. The

measured value was 13 feet and 2 inches from fl oor to the roof at this point. Underground fracture mapping is also an integral part of th e monitoring program. Fractures in the underground waste panels are typically less than 1⁄4 inch wide , and in the main drifts, which are open for longer period, fractures are typically 2 to 3 inch es wide, and are addressed by rock bolting in a regular pattern.

During the afternoon of May 11, inspectors visite d the geomechanical engineering department offices. The electronic entry of the morning’s convergence data from the handwritten sheet was

verified. DOE concluded on the basis of measuremen ts that the rate of deformation is consistent and predictable. The deformation mechanis m remains unchanged and the effects of RH

boreholes in Rooms 6 and 7 of Panel 7 are cons istent with the predicted values. DOE also

indicated that with the advan cement in mining, the monitoring stations are being relocated. Panel 4 is no longer being monitored and th e measurements are taken in Panel 5 and 6. Instruments are being installed in Panel 7. EP A reviewed all convergence data for S2750- W93 and E300-S2180 (JPW-20110511-08, -09) and data from the remotely monitored wire extensometer 51X-GE-00389 placed at W390-S3480 (JPW-20110511-10).

Based on these inspection activitie s, EPA concluded that the proc edures are adequate for proper

measurements and did not iden tify any concerns or findings.



### 4.2 Monitoring of Hydr ological Parameters DOE committed to measure two hydrological pa rameters in the CCA: Culebra groundwater composition, and changes in the Culebra groundwat er flow direction (a s indicated by Culebra fresh water heads). Culebra groundwater chemistr y and potentiometric head measurements are performed by members of the WIPP envir onmental monitoring program. Programmatic functions and responsibilit ies are outlined in the WIPP Groundwater Monitoring Program Plan

, WP 02-1 Revision 10 (EPA Inspection ID: KME-M2011-GW09). Results of this program are published in the annual WIPP Site Environmental Report for 2009, DOE/WIPP-10-2225 (EPA Inspection ID: KME-M2011-GW10) denoted herein as the ASER. The ASER describes and presents environmental programmatic data wh ich the groundwater monitoring program falls

under.

Culebra Groundwater Composition
Changes in the Culebra groundwater compositi on monitoring program since EPA’s July 2010 inspection were presented by Rick Salness, (WRES) WIPP’s Ground Water Monitoring Program lead staff member, during the May 10 th opening presentation (E PA INSPECTION ID: KMEM2011-GW14). The following changes or soon to be implemented changes are:

1. Well WQSP-6A is no longer used as part of the semi-annual monitoring program, therefore there is one less water quality sampling well used since the 2010 inspection.8 2. Basic water quality chemistry testing is now performed only on Magenta wells H-2b2, H4c, H-6c, and H-9c.

3. The program is in the process of modifying the hazardous waste facility permit to reduce the number of required serial sampling parameters.

On the morning of May 11 th , the EPA inspector arrived at well WQSP-5. The field team consisted of Robin Spoon and Richie Jimenez. Ri ck Salness also was in attendance. The field team was on the third day of ta king groundwater serial samples for this well and in the process of taking end measurements, collecting final groun dwater samples, and packing samples for shipment to an offsite laboratory. The EPA inspector observed the field team collecting groundwater serial samples and performing tota l alkalinity, anion/cat ion balances per the following technical procedures:

Groundwater Serial Sample Analysis (WP 02-EM1005 Rev 7, Inspection ID: KMEM2011-GW11) Serial and Final Sample Analysis (W P 02-EM1006 Revision 8, Inspection ID: KMEM2011-GW12)

The inspector observed the team collecting ‘final’ serial sa mples per procedure WP 02-EM1006. The inspector compared observed activities to procedures specified in WP 02-EM1006, Sections

1.0 thru 1.28—Collection of Se rial Groundwater Samples and Sections 2.0 through 2.1— Preserving Final Groundwater Samples . The procedure provides explicit steps for sample collection, labeling, preservation and filling ou t sample documentation and chain of custody forms. During this inspection the EPA inspect or observed staff follo wing the procedure and completing appropriate steps for sample collect ion, labeling, preservation and documentation.

The EPA inspector observed the field team meas uring groundwater pH, al kalinity and divalent cations, and dissolved iron as specified in WP 02-EM1005 Rev 7 pages 61, 63, and 64. The team followed protocols as described below:

The inspector observed the final alkalinity ti tration, reported on page 61 of WP 02-EM1005 Rev 7, and examined Excel spreadsheet formulae (EPA Inspection ID: KME-M2011-GW03, page 1) for alkalinity against those specified in pa ges 33-37 of WP 02-EM1005 Rev 7. The inspector cross-checked total alkalinity as calculated by the formula given in procedure WP 02-EM1005 Revision 7 (Step 6.6.8, page 36) against Excel calculations (EPA Inspection ID: KME-M2011- GW03, page 2), Serial Sampling ALK Calc Sheet). The field team accurately followed subject protocol to determine total alkalinity; spreadsheet formulas calculate alkalinity as specified in procedure.

The inspector observed the measurement of divale nt cation (Ca and Mg) concentrations in water samples per WP 02-EM1005 Rev 7, Section 8, pages 40-46. The inspector cross-checked the

total divalent cation concentra tion formula given in procedure WP 02 EM-1005 Revision 7 (Step 8.15, page 44) against Excel calculations (EPA Inspection ID: KME-M2011-GW04, pages 2 &3 Serial Sampling ALK Calc Sheet). The field team accurately meas ured and calculated divalent cation concentrations as speci fied in the procedure.9 The inspector cross-checked the total iron fo rmula given in procedure Step 9.19, WP 02 EM1005 Revision 7 (Step 9.1.9, page 51) against Ex cel calculations (EPA Inspection ID: KMEM2011-GW05, Serial Sampling Fe Calc Sheet). The inspector determined that the iron concentration formula specified in procedure is accurately represente d in the spreadsheet.

During the inspection, EPA noted that the probe rinse water accumulated in beakers and could easily result in the probe tip becoming immers ed during repeated ri nses. EPA suggested procedure WP 02-EM1005 Rev 7, Groundwater Serial Sample Analysis , be modified to direct

staff to discard rinse water after each rinse. Rick Salness agreed to this revision.

In summary, the EPA inspector found that th e field team followed and implemented proper procedures for testing groundwater chemistry.

Review of Culebra Groundwater Flow
During the 2011 inspection, the EPA inspector re quested information about changes in the program over the past year. In the May 10 th opening presentation Rick Salness, (WRES) WIPP’s Ground Water Monitoring Program lead staff memb er, reported the following changes in WIPP monitoring wells since the 2010 inspecti on (EPA INSPECTION ID: KME-M2011-GW14).

These are summarized below:

 Well H-9b was plugged in September 2010

 H-9bR—a replacement well for H-9b—was dr illed and completed in September.

 Well H-9c was reconfigured, in September 2010, to monitor only the Magenta formation.

The current well monitoring network consists of the following wells:

Formation Number of Wells Change since July 2010

Culebra 47 +1 Magenta 11 0 Magenta/Culebra (dual completion) 1 -1 Dewey Lake 1 0 Bell Canyon 2 0 Santa Rosa/Dewey Lake contact 20 0

The EPA Inspector reviewed the Waste Isolation and Pilot Plant Site Environmental Report for 2009, DOE/WIPP-10-2225 , flow direction maps, well location maps, water level measurements, and water chemistry data (EPA Inspecti on ID: KME-M2011-GW10). The EPA inspector compared the differences between the 2008 and 2009 Culebra potentiometric maps [ DOE/WIPP09-2225 , pages 6-20 & 6-21, Inspection ID: CO B-M2010-S18) and DOE/WIPP-10-2225, pages

162 and 163 (EPA Inspection ID: KME-M2011-GW10- C6)]. The reported groundwater contours, flow direction, and particle travel-time to the WIPP land withdrawal boundary are relatively unchanged. The minor differences in estimated travel times are attributed to the normal and cyclical variability in freshwater h eads, a general decrease in heads (now in a quiescent phase ‘settling’ from the transient perturbation created by WIPP-site drilling and testing activities), and other re gional anthropogenic activities aff ecting the Culebra water table10 (e.g., mining, drilling, and borehole e xploration activities). Of not e, the hydrographs in the 2009 annual report appear to be the same as those gi ven in the 2008 report a nd this issue was brought up in a discussion with Rick Salness. Rick Salnes s acknowledged this was an editorial error. An

errata to the 2009 ASER will be issued to include the updated hydrographs.

The EPA inspector reviewed Construction of the Potentiometr ic Surface Map for the Annual Site Environmental Report a nd Shallow SubSurface Water (WP 02-EM1025, Revision 2; EPA INSPECTION ID: KME-M2011-GW13) which is desi gnated as the default procedure used to generate the Culebra potentiometric map for the AS ER. After some discussion with the staff the inspector realized the actual procedure used to generate the Culebra map for the ASER is produced and followed by Sandia National Laborator ies. The Inspector reviewed Sandia National Laboratories (SNL) Activity/Project Specific Procedure (Kuhlman, K. 2009. Sandia National Laboratories, SNL SP 9-9), Preparation of Culebra Potentiometric Surface Contour Map , Revision 0 (EPA INSPECTION ID: KME-M2011- GW14), used to generate the Culebra freshwater heads and particle tracking reported in th e annual ASER document. The procedure was reviewed and cross-checked against the poten tiometric map and water level elevation data, both presented in Figure 6.12 and Table 6.3, resp ectively, of the ASER report (DOE/WIPP-10-

2225

, Figure 6.12 Model-Generated June 2009 Freshwat er Head Contours (5-Foot Contour Interval) in the WIPP Vicinity with Blue Wate r Particle Track From Waste Handling Shaft to

WIPP LWB and Table 6.3, Water Elevation for the June 2009 Potentiometric Surface Calibration, Culebra Hydraulic Unit ). To do this comparison it was first necessary to convert the

freshwater head values from feet to meters. Freshwater head values for each well corresponded with the potentiometric contour lines at the map location of each well.

The EPA inspector found that it was unclear wh ich procedure is used to create the Culebra potentiometric map used in the ASER. The review of WP 02-EM 1002 and found it to have

‘dead-end’ directions. While this is not a breach in the mon itoring and recording of Culebra groundwater flow direction

, it is difficult to trace when the st eps of this procedure are invoked, and clarification of some ‘dead-end’ steps requi red additional discussion among DOE staff. EPA suggests DOE modify procedure WP 02-EM1025 to re flect its actual use, clarify potential deadend directions, and direct the reader to the specif ic procedure used to generate the annual Culebra potentiometric map reported in the ASER.11 

### 4.3 Monitoring of Wast e Activity Parameters
In the CCA, DOE committed to monitor the total radioactivity of waste emplaced in WIPP, so that total activity and materials do not violat e limits set by the WIPP Land Withdrawal Act and the most recent compliant performance assess ment. Waste activity deposited in the WIPP repository is part of the data collected for each container shipped to WIPP and stored in the WIPP Waste Data System (WDS). . The WDS is a database sy stem used to track total activity and waste components (e.g., ferr ous and non-ferrous metals, or ganic materials and MgO) emplaced in WIPP and is used to generate report s on the transuranic (TRU) waste sent to WIPP. The requirements for the WDS are discussed in the WIPP Waste Data System Program and Data Management Plan , WP 08-NT.01 Revision 22 (E PA INSPECTION ID: KME-M2011- WACT07). DOE reports annual waste activ ity information and is given in the Annual Change Repor t 2009/2010, Table 3 (DOE/WTS Nove mber 15, 2010. EPA INSPECTION ID: KMEM2011-WACT14).

On May 11, 2011, while in the waste handling ro om, EPA Inspectors observed RH waste container number AE0085 (Fi gure 1, EPA INSPECTION ID: KME-M2011-WACT07) undergoing the remote tracking and scanning pro cess in preparation for repository placement within the next 24 hours. During the May 12, 2010 inspection of the WDS database EPA inspectors queried the WDS to see when this canister was emplaced in the repository. The database query report (EPA INSPECTION ID: KME-M2011-WACT 04) indicates RH container AE0085 waste was emplaced in the reposit ory on May 12, 2011 as appropriate.

The WDS system tracking CH/RH waste activity em placed in the repository was spot-checked. Inspectors queried the data base for time periods wh en waste was received in Panel 4, then cross checked this activity with a que ry bookending this timeframe. EP A Inspectors requested a query for waste activity in Panel 4 during the time period 01/ 01/1999 through 12/31/2009 (EPA INSPECTION ID: KME-M2011-WACT03), to assure c onsistency in reported waste activity in

Figure 1 ‐ Monitor Picture of RH Canister In Waste Handling Room Undergoing Final Check Before Repository Placement (EPA Inspection ID:

KME

‐ M2011

‐ WACT07)12 Panel 4 over different time frames. Using the generated query (EPA INSPECTION ID: KMEM2011-WACT03), a cross-check of reported WDS activity was performed by running additional queries of waste activity for different time fram e. These query reports are listed below:

 01/01/1999 thru 12/31/2009 (EPA IN SPECTION ID: KME-M2011-WACT01)

 01/01/2009 thru 12/31/2009 (EPA IN SPECTION ID: KME-M2011-WACT02)

 01/01/ 2009 thru 05/12/2011 (EPA IN SPECTION ID: KME-M2011-WACT05)

The EPA inspector reviewed activ ities reported for waste received in Panel 4 Rooms 1 through 7 over the queried time-frames to assure that reported activities for each time span were in agreement and corroborate one another. The four report queries corroborate consistent values for the given time-frames. From this spot-check it is concluded that the WDS appears to adequately report for the activity emplaced in the rooms and panels.

4.4 Monitoring of Drilling Related Parameters

DOE committed to measure two dr illing related parameters in the CCA: the drilling rate and the probability of encountering a Castile brine reservoir. These pa rameters are measured as part of

the Delaware Basin Drilling Surveillance Plan , WP 02-PC.02 Revisi on 3 (EPA INSPECTION ID: KME-M2011–DB08). The surv eillance program measures a nd records many parameters related to drilling activities around the WIPP site. The results of the surveillance program are documented quarterly and comb ined in the annual report Delaware Basin Monitoring Annual Report, December 2010, DOE/WIPP-10-2308 (EPA Inspection ID: KME-M2011–DB01). The annual report provides data covering the period from September 1, 2009 to August 31, 2010. Drilling data is collected us ing procedure WP 02-EC3002 Rev 4, Delaware Basin Drilling Database Upgrade Program (EPA INSPECTION ID: KME-M2011-DB10).

An update and summary of Delaware Basin drill ing activities was pres ented during the May 10 th

, 2011 opening briefing (EPA Inspection ID: KM E-M2011-DB07). EPA Inspectors reviewed the information provided in the Delaware Basin Annual Monitoring Report (DOE-WIPP-10-2308, EPA Inspection ID: KME-M2011-DB13) and Delaware Basin Monitoring Quarterly Report (EPA Inspection ID: KME-M2011-DB11). EPA inspect ors observed how the database is updated to track weekly drilling activities in the basin using the procedure Delaware Basin Drilling Database Upgrade Process WP 02-EC3002 Rev 4 (EPA INSPECTION ID: KME-M2011– DB10). The procedure is used to step through th e process to update databases with information

from various commercial and state sources. Ad ditionally, EPA reviewed the drilling surveillance database and examined changes in drilling rates, permitted wells, and active injection wells. The inspectors reviewed Texas and New Mexico reports, well database listings and maps of oil and gas wells around WIPP (EPA Inspection ID: KME-M2011-DB02, KME-M2011-DB03, KMEM2011-DB04, KME-M2011-DB05, and KME-M2011-DB 06). During staff interviews and

demonstrations of the Delaware Basin database , EPA inspectors verified that DOE adequately tracks drilling rates and Castil e brine encounters near WIPP, a nd reports results annually and quarterly.

4.5 Monitoring of Subsidence Parameters

DOE committed to measure surface subsidence at th e WIPP site. This parameter is documented13 as part of the WIPP Underground and Surface Surveying Program , WP 09-ES.01 Revision 5 (EPA INSPECTION ID: KME-M2011-SUB03). DOE performs subsidence leveling surveys at the site annually during pre-closure operations. Nine vertical survey control loops using 48 subsidence marker monuments are completed each year to determine the degree of subsidence above the repository footprint. The results of this program are reported annually in the WIPP Subsidence Monument Leveling Survey 2010 , DOE/WIPP 11-2293 (EPA INSPECTION ID: KME-M2011-SUB01).

Subsidence staff demonstrated the steps followed in procedure Subsidence Survey Data Acquisition Report , WP 09-ES4001, Revision 1, Secti on 2 (EPA INSPECTION ID: KMEM2011-SUB02) used to process raw field survey loop data, download the data from the survey module to the computer, and convert to r eadable surface elevations (JPW20110511-11). The

surface elevations are reported in the annual WIPP Subsidence Monument Leveling Survey 2010

, DOE/WIPP 11-2293(EPA INSPECTION ID KME-M2011-SUB01). DOE demonstrated that the subsidence parameters area measured adequa tely and results ar e reported yearly.



### 5.0 Summary of Results

Based on program documents, interviews, and fi eld demonstrations during the inspection, EPA concludes that the monitoring program covers th e ten monitoring parameters required by EPA’s 1998 Certification Decision. This inspection dete rmined that monitoring sample collection, and sample/data analysis procedures were complete and appropriate; that staff were adequately trained and implemented the procedures adequa tely; and that appropriate quality assurance measures are applied. EPA continues to find that DOE has maintained adequate parameter monitoring during the past year a nd has appropriate procedures and requirements in place. EPA has no findings or concerns.14 

### Attachment A: Inspection Plan and Checklist

WIPP Monitoring Inspection Plan 40 CFR 194.42 for the year 2011 Purpose : Verify that the Department of Energy (DOE) can demonstrate that the Waste Isolation Pilot Plant (WIPP) is monitoring the parameter commitment s made in the documentation to support the EPA’s certification decision, in particular CCA , Volume 1, Section 7.2, Table 7.7 and Appendix MON. This inspection is conducted unde r the authority of 40 CFR 194, Section 21.

This inspection is part of EPA’s continued overs ight to ensure that WIPP can, in fact, monitor the performance of significant parame ters of the disposal system.

Scope: Inspection activities will include an examinati on of monitoring and sampling equipment both on and off site, and in the underground. A revi ew of sampling procedures and measurement techniques may be conducted. Quality assura nce procedures and documentation for each of

these activities will also be reviewed.

Focal Areas of This Year’s Inspection:

- What has changed in the monito ring program this past year?

- What documentation and procedures have changes?

- Update the monitoring program a nd results for the past year.

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

Location : This inspection will be held at the WIPP facility location twenty-six miles south east of Carlsbad, New Mexico and the surrounding vicinity as needed.

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

Expected Date : Week of May 13, 2011.

Documents For Review: The latest versions of any documen tation and/or procedures related to the DOE monitoring program.15 2010 Monitoring Inspection Checklist

Checklist for Geotechnical Moni toring Commitments – May 2011

Monitoring Commitments – May 2011 Geotechnical Parameters

# Question Comment (Objective Evidence) Result

1 Does DOE demonstrate that they have implemented plans/programs/procedures

to measure -

a) Creep Closure;

b) Extent of Deformation;

c) Initiation of Brittle Deformation and

d) Displacement of Deformation

Features

during the pre-closure phase of operations as specified in the CCA part of the geomechanical monitoring system?

(CCA, Volume 1, Table 7-7; App MON, Table MON-1) 40 CFR 194.42 (c) and (e) Objective evidence given reviewing the following procedures and reports – Preparation of 2010 Culebra Potentiometric Surface Contour Map

, Revision 2, Task Number:1.4.2.3, Report Date: 4/6/2011, (ERMS555318)

Waste Isolation Pilot Plant Annual Site Environmental Report for 2009 (DOE/WIPP-10-2225) Construction of the Potentiometric Surface Map for the Annual Site Environmental Report and Shallow SubSurface Water , Revision 2, WP 02- EM1025, 08/03/10 (while this is not a quality affecting observation, this procedure should be revised. EPA suggests DOE revise procedure to provide clarity as what parties generate the ASER Culebra Potentiometric map) Results are documented annually in the DOE/WIPP 10-2225 and Figure 6.12, and Appendix F. SAT

Does DOE demonstrate that they have implemented an effective quality assurance program for item 1 above? 40

CFR 194.22 During the 2011 inspection the EPA inspector evaluated the quality assurance program and found it to be adequate. SAT

3 Does DOE demonstrate that the results of the geotechnical investigations are reported annually? (CCA, App. MON, Page MON-10) WP 07-01, Section 3.2 requires that analysis be performed annually and results are published in the annual geotechnical analysis report (DOE/WIPP 09-3177). SAT16 Checklist for Hydrologic Mo nitoring Commitments – May 2011

Monitoring Commitments – May

2011 Hydrological Parameters

# Question Comment (Objective Evidence) Result 1 Does DOE demonstrate that they have implemented plans/programs/procedures to measure

– a) Culebra Groundwater Composition; (CCA, Volume 1, Table 7-7; App MON, Table MON-1) 40 CFR 194.42 (c) and (e) Objective evidence given reviewing the following procedures and reports: Groundwater Serial Sample Analysis (WP 02-EM1005 Rev 7) Serial and Final Sample Analysis (WP 02-EM1006 Rev 8) The inspector observed the collection of groundwater serial samples and determining groundwater constituents per above procedures. Given this spot check, the EPA finds that DOE follows and implements adequate procedures and programs for testing groundwater chemistry. SAT

b) Change in Culebra Groundwater Flow Direction during the pre-closure phase of operations as specified in the CCA part of WIPP’s groundwater monitoring plan? (CCA, Volume 1, Table 7-7; App MON, Table MON-1) 40 CFR 194.42 (c) and (e) Objective evidence given reviewing the following procedures and reports – Preparation of 2010 Culebra Potentiometric Surface Contour Map

, Revision 2, Task Number:1.4.2.3, Report Date: 4/6/2011, (ERMS555318)

Waste Isolation Pilot Plant Annual Site Environmental Report for 2009 (DOE/WIPP-10-2225) Construction of the Potentiometric Surface Map for the Annual Site Environmental Report and Shallow SubSurface Water , Revision 2, WP 02- EM1025, 08/03/10 (while this is not a quality affecting observation, this procedure should be revised. EPA suggests DOE revise procedure to provide clarity as what parties generate the ASER Culebra Potentiometric map) Results are documented annually in the DOE/WIPP 10-2225 and Figure 6.12, and Appendix F.17 2 Does DOE demonstrate that they have implemented an effective quality assurance program for item 1 above? (CCA, App MON, Page MON-22) 40

CFR 194.22 During the 2011 inspection the EPA inspector evaluated the quality assurance program and found it to be adequate. SAT

3 Does DOE demonstrate that the results of the groundwater monitoring program are reported annually? (CCA, App. MON, Page MON-22) Objective evidence given in the Waste

Isolation Pilot Plant Annual Site Environmental Report for 2009, DOE/WIPP-10-2225, (ASER). The document provides annual groundwater elevations for 47 wells completed in the Culebra and used this

well data to create the Culebra regional and local potentiometric maps

around the WIPP LWB. SAT18 Checklist for Waste Activity Mo nitoring Commitments – May 2011

Monitoring Commitments – June

2011 Waste Activity Parameters

# Question Comment (Objective Evidence) Result 1 Does DOE demonstrate that they have implemented plans/programs/procedures to measure -

a) Waste Activity?

(CCA, Volume 1, Table 7-7; App MON, Table MON-1) 40 CFR 194.42 (c) and (e) The WIPP Waste Data System Program and Data Management Plan,

WP 08-NT.01 Rev22 Section 6.0(EPA INSPECTION ID: KMEM2011-WACT07) describes how the

WDS is used to measure and store waste activity information. WWIS User’s manual, DOE/WIPP 09-3427Rev 2 (EPA INSPECTION ID: KMEM2011-WACT12) documents procedures used to gather, store, and process waste activity information

. WDS (WWIS) staff demonstrated the use of the WDS and generated numerous waste related reports (EPA

INSPECTION IDS: KME-M2011- WACT01, KME-M2011-WACT02,KME-M2011-WACT03, KMEM2011-WACT04, KME-M2011- WACT05). These activities demonstrate that waste activity is adequately monitored. SAT

2 Does DOE demonstrate that they have implemented an effective quality assurance program for item 1? (CCA, App WAP, page C-30) 40 CFR 194.22 The EPA inspector evaluated the quality assurance process and found it to be adequate. SAT

3 Does DOE demonstrate that the results of the waste activity parameters are reported annually? (CCA Volume, Section 7.2.4 Reporting) The WIPP Waste Data System Program and Data Management Plan,

WP 08-NT.01 Rev22 Section 6.0(EPA INSPECTION ID: KMEM2011-WACT07) specifies that waste activities area reported annually.

Table 3 in the Annual Change Report

2009/2010 (EPA INSPECTION ID: KME-M2011-WACT14) provides objective evidence that the waste activity parameters are reported. SAT19 Checklist for Drilling Rate Mo nitoring Commitments – May 2011

Monitoring Commitments – June

2011 Drilling Related Parameters

# Question Comment (Objective Evidence) Resul

t 1 Does DOE demonstrate that they have implemented plans/programs/procedures to measure -

a) Drilling Rate; and

b) Probability of Encountering a Castile

Brine Reservoir?

(CCA, Volume 1, Table 7-7; App MON, Table MON-1) 40 CFR 194.42 (c) and (e) The Delaware Basin Drilling

Surveillance Plan , WP 02-PC.02 Rev3 (EPA INSPECTION ID: KMEM2011–DB08), documents the program to measure, record, report, and the QA requirements for these activities. Quality assurance requirements are documented in

Section 7.0 of WP 02-PC.02 Rev 3.

The Delaware Basin Drilling Database Upgrade Process WP 02- EC3002 Rev 4 (EPA INSPECTION ID: KME-M2011–DB10) documents the process used to update databases

with information from various

commercial and state sources. Drilling rate and Castile brine encounter data are reported annually in

the Delaware Basin Monitoring Annual Report DOE/WIPP 10-2308(EPA INSPECTION ID: KMEM2011–DB01) in Sections 2.5 and

2.6. WIPP staff discussed changes during the past year (KME-M2011-DB07). DB staff reported on brine encounters, drilling rate calcula tions, and provided maps of drilling activities near WIPP (KME-M2011-DB02, KME-M2011- DB03 and KME-M2011-DB04). Staff also provided the latest listing of the

New Mexico and Texas well databases (KME-M2011-DB05, KME-M2011- DB06). They demonstrated that DOE is adequately monitoring these parameters through the Delaware Basin monitoring program. SAT20 2 Does DOE demonstrate that they have implemented an effective quality assurance program for item 1 above? (CCA, App DMP, page DMP-9) 40

CFR 194.22 During this inspection the EPA inspector evaluated the quality assurance program and found it to be adequate. SAT

3 Does DOE demonstrate that the results of the drilling related parameters are reported annually? (CCA Volume, Section 7.2.4 Reporting; App DMP, page DMP-9) Delaware Basin Monitoring Annual Report, December 2010, DOE/WIPP10-2308 Section 6.0 documents that results are reported annually.

DOE/WIPP 08-2308 verifies that these parameters are updated and reported annually. SAT21 Checklist for Subsidence Monitoring Commitments – May 2011 Monitoring Commitments – June

2011 Subsidence Monitoring Parameters

# Question Comment (Objective Evidence) Result 1 Does DOE demonstrate that they have implemented plans/programs/procedures to measure -

a) Subsidence measurements?

(CCA, Volume 1, Table 7-7; App MON, Table MON-1) 40 CFR 194.42 (c) and (e) WIPP Underground and Surface Surveying Program WP 09-ES.01 Rev 05(KME-M2011-SUB03) documents the program used to measure, record, document, report subsidence monitoring; the te chnical program description is given in Section 3.3, QA requirements for these activities are provided in Section 4.0. The Subsidence Survey Data Acquisition Report, WP 09-ES4001 Rev 1 (KMEM2011-SUB02) documents the process for acquiring subsidence data (Section 1.0); updating the database and publishing the annual subsidence report (Section 2.0). The WIPP Subsidence Monument Leveling Survey - 2010 DOE/WIPP 11-2293 (KME-M2011-SUB01) provides objective evidence that DOE annually reports this parameter and results of this program (Section 5.0). Site staff demonstrated that procedures are adequately implemented, how raw field survey data is reduced to useful survey data. DOE has demonstrated that subsidence is adequately

monitored at the site. SAT

2 Does DOE demonstrate that they have implemented an effective quality assurance program for item 1? 40 CFR

194.22 During this inspection the EPA inspector evaluated the quality assurance program and found it to be adequate. SAT

3 Does DOE demonstrate that the results

of the subsidence measurements are reported annually? (CCA Volume, Section 7.2.4 Reporting) The DOE report WIPP Subsidence Monument Leveling Survey 2010

, DOE/WIPP 11-2293 (KME-M2011- SUB01) demonstrates that subsidence results are published annually. SAT22 Attachment B: Documents ReviewedDocuments Received and Reviewed During Inspection194.42 Monitoring InspectionMay 2011EPA Inspection ID# Document TitleDOE ID# SourceHydrologic DocumentsKME-M2011-GW09WIPP Groundwater Monitoring Program PlanWP 02-1 Revision 10DOE/WIPPKME-M2011-GW10WIPP Site Environmental Report for 2009DOE/WIPP-10-2225DOE/WIPPKME-M2011-GW14Oral Presentation by Rick SalnessN/ADOE/WIPPKME-M2011-GW11Groundwater Serial Sample AnalysisWP 02-EM1005 Rev 7DOE/WIPPKME-M2011-GW12Serial and Final Sample AnalysisWP 02-EM1006 Rev 8DOE/WIPPKME-M2011-GW3p. 61, Groundwater Serial Sample AnalysisWP 02-EM1005 Rev 7DOE/WIPPKME-M2011-GW04Attachment 7: Serial Sampling Field Laboratory Report for AlkalinityWP 02-EM1005 Rev 7, Att. 7, p. 61DOE/WIPPKME-M2011-GW13Construction of the Potentiometric Surface Map for the Annual SiteEnvironmental Report and Shallow SubSurface WaterWP 02-EM1025, Rev 2DOE/WIPPKME-M2011-GW14Preparation of Culebra Potentiometric Surface Contour Map SNL SP 9-9,Revision 0Kuhlman, K. 2009. SNL SP 9-9DOE/SNLMonitoring of Waste ActivitiesKME-M2011-WACT07WIPP Waste Data System Program and Data Management PlanWP 08-NT.01 Revision 22DOE/WIPPKME-M2011-WACT14Annual Change Report 2009/2010, Table 3DOE/WIPPKME-M2011-WACT07Figure 1 - Monitor Picture of RH Canister In Waste Handling RoomN/ADOE/WIPPKME-M2011-WACT04The database query reportN/ADOE/WIPPKME-M2011-WACT03WDR - Waste Data System, Emplacment History Overview Report Panel 4(waste activity query period 01/01/1999 - 12/31/2009)N/ADOE/WIPPKME-M2011-WACT01Waste Isolation Pilot Plant Nuclide Report Generated on May 12, 201111.25 AM (Selection Criteria, Start Date: 01/01/1999 End Date:12/31/2009)N/ADOE/WIPPKME-M2011-WACT02Waste Isolation Pilot Plant Nuclide Report Generated on May 12, 201111.28 AM [Selection Criteria, Start Date: 01/01/2009 End Date:12/31/2009]N/ADOE/WIPPKME-M2011-WACT05Waste Isolation Pilot Plant Nuclide Report Generated on May 12, 201111.39 AM [Selection Criteria, Start Date: 01/01/1999 End Date:05/12/2011]N/ADOE/WIPPKME-M2011-DB02Delaware Basin Annual Monitoring ReportDOE-WIPP-10-2308DOE/WIPPKME-M2011-DB11Delaware Basin Monitoring Quarterly ReportN/ADOE/WIPPDelware Basin DocumentsKME-M2011–DB08Delaware Basin Drilling Surveillance PlanWP 02-PC.02 Rev 3DOE/WIPPKME-M2011–DB01Delaware Basin Monitoring Annual Report, December 2010DOE/WIPP-10-2308DOE/WIPPKME-M2011-DB10Delaware Basin Drilling Database Upgrade ProgramWP 02-EC3002 Rev 4DOE/WIPPKME-M2011-DB07DOE presentation: Delaware Basin drilling activitiesN/ADOE/WIPPKME-M2011-DB02Delaware Basin Annual Monitoring ReportDOE-WIPP-10-2308DOE/WIPPKME-M2011-DB11Delaware Basin Monitoring Quarterly ReportN/ADOE/WIPPSubsidence DocumentsDOE/WIPPKME-M2011-SUB03WIPP Underground and Surface Surveying ProgramWP 09-ES.01 Rev 5DOE/WIPPKME-M2011-SUB01WIPP Subsidence Monument Leveling Survey 2010DOE/WIPP 11-2293DOE/WIPPKME-M2011-SUB02Subsidence Survey Data Acquisition Report,WP 09-ES4001, Rev 1DOE/WIPPJPW-20110511-11DIGILEV output file, 3pp.GeotechnicalN/AGeotechnical Analysis Report for July 2009 - June 2010, DOE/WIPP 10-3177,Volumes One and Two(Support Data)DOE/WIPP 10-3177, Vol. I and IIDOE/WIPPN/AManually Acquired Geomechanical Instrumentation Data, TechnicalProcedure,WP 07-EU1301,Revision 6,03/19/08WP 07-EU1301DOE/WIPPN/AGeomechanical Instrument Data Processing, Technical Procedure, WP 07-EU1303,Revision 3,06/18/08WP 07-EU1303, Rev 3DOE/WIPPN/AInstalling Convergence Reference Points, WP 07-EU1304, TechnicalProcedure,Revision 5,10/19/09WP 07-EU1304, Rev 5DOE/WIPPN/AInstalling Rock Bolt Load Cells, Technical Procedure, WP 07-EU1306,Revision 4,10/19/09WP 07-EU1306, Rev 4DOE/WIPPN/AInstalling Wire Extensometers, Technical Procedure, WP 07-EU1308, Rev2,10/19/09WP 07-EU1308, Rev 2DOE/WIPPN/AGeologic and Fracture Mapping Of Facility Horizon Drifts, TechnicalProcedure,WP 07-EU1001,Revision 3,7/21/10WP 07-EU1001, Rev 3DOE/WIPPJPW-20110511-08Convergence graph S2750-W0093N/ADOE/WIPPJPW-20110511-09Convergence graph E300-S2180N/ADOE/WIPPJPW-20110511-10Extensiometer graph 51X-GE-00389, W390-S3480N/ADOE/WIPP