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
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 Table of Contents 

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

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

3.0 Inspection Team, Observers, 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 annual inspection of the 

Department of Energy (DOE) Waste Isolation Pilot Plant (WIPP) May 10 to 12, 2011 as part of 

its continued oversight program. This inspection 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 standard found at 40 CFR 191.03, Subpart A. 

 EPA reviewed DOE’s ability to monitor radioactive 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 continued moisture problems and salt loading at 

the Station A sampling location in the air exhaust shaft. EPA inspectors examined WIPP’s 

emission control devices and methods used to estimate radiation doses to the public. In addition, 

EPA inspected radiation sample locations and equipment, 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 increase probe cleaning frequency to weekly as 

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

at Station A. DOE continues to have an effective radiation sampling program because of the 

continued diligence of site staff and can calculate 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 meteorological 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 the active waste emplacement panel in the 

underground. EPA also addressed the site’s ability to characterize a radiological release during 

an emergency, and the tracking of samples and analytical results through the WIPP laboratory. 

EPA had no findings or concerns during the inspection. 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 place in the vicinity of 

the exhaust shaft, EPA may stipulate weekly probe changes if A-1 is being used as a backup.
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3.0 Inspection Team, Observers, and Participants

 The inspection team consisted of five EPA staff. Thomas Kesterson 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, with an opening meeting that included 

presentations on changes in air monitoring and WIPP laboratory activities. Site staff discussed 

changes in the program since the last EPA inspection in July 2010. These presentations included 

the following updates and changes to the program: 

- PM 364001, revised in 2010 to stipulate more frequent probe pulls at Station A, was followed. 

With a maximum probe pull interval of two weeks, there 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, 
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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 the 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 allowing many inputs to be made to the Hotspot code upon arrival 

in the EOC, before specific information about a given event is available. 

- Study by Mike Gross, “Representative of Samples by Shrouded Probes in the Exhaust Shaft at 

the WIPP”, examining the current ability of Station A to collect representative samples, remains 

in final draft form. 

The EPA inspection team reviewed procedures, interviewed site staff, and observed 

activities such as filter and probe changes to verify the effective 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 probe changes, reviewed the underground RADOS 

CAMs, walked through an emergency response scenario with consequence assessment staff, and 

examined procedures guiding the processing of samples at the WIPP radiochemistry laboratory. 

4.2 Stations A, B, and C 

Station A, which samples unfiltered air exhausted from the WIPP underground, has been a focus 

of EPA in several past inspections, due to the tendency of salt to occlude the sampling probes, 

with the potential to render aerosol samples unrepresentative. This has been 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 and filter changes at Station A. Because Skid 

A-2 was down for maintenance of its sample transport 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 excessive salt occlusion. Each fixed air sampler 

(FAS) was calibrated and flow rates were appropriate. The inspection team visited Station B and 

the newly-refurbished Station C to verify calibration dates and flow rates. 

 
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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-handling 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, inspectors observed the continuous air monitors 

(CAMs) placed at the exhaust of Panel 6 (the active waste panel) 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 sticker had not been changed. 

4.4 WIPP Laboratory 

EPA also toured the WIPP laboratory, which supports annual National Emissions Standards for 

Hazardous Air Pollutants (NESHAP) reporting and emergency response activities at WIPP. 

Inspectors toured the laboratory itself and were given a presentation 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 NESHAP report for February, 2011. Inspectors 

verified that the proper QA and chain-of-custody forms had been used; that signatures were in 

place for data entry, review, and finalization; and that sample tracking logs were adequate. 

Specifically, samples were collected using 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 activities 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 conditions. 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 possible radiation doses to members of the public 
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due to WIPP site operation. The inspection checklist included as Attachment 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 inspection activities documented in this report, EPA 

concludes that DOE continues to adequately implement a radiological monitoring and sampling 

program for WIPP disposal operations in which it collects representative samples and 

appropriately performs calculations to estimate potential releases to the public. The results of 

this program, documented in the Annual Periodic Confirmatory Measurement Compliance 

Report for Calendar Year 2010 (RES 11-579) show that “the effective dose equivalent (EDE) 

value to the maximally exposed individual resulting 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. 
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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 Energy (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 with the limits expressed in 40 CFR 191.03. 

Scope: 

The scope of this inspection includes all activities 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, specifically during the past year of site operation. Inspection 

activities will include an examination of monitoring procedures and sampling equipment both on 

and off site, and in the underground. 

The purpose of this inspection is to verify and confirm that DOE at WIPP has complied with the 

“Compliance reporting” expectations of EPA’s GUIDANCE 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 sampling 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 changes were discussed to evaluate and 

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

 With continued moisture in the exhaust 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 laboratory standards used? 

 Provide a presentation of the process and procedures used to calculate off-normal 

potential release during operations. Describe the process 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 facility located twenty-six miles south east 
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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 before 5:00 p.m. with a closeout session. 

Date: May 10-12, 2011. 

 

Information Requested: Provide documentation and procedures related to Subpart A 

compliance activities as in past years. Before the inspection, provide information that describes 

how measurements are taken, and complete documentation that shows how compliance 

calculations are performed with an explanation of all input parameters and their derivation. As 

soon as it becomes available, please provide to EPA the 2010 Annual Safety Analysis Report. 
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# CHECKLIST QUESTION May 2011 40 CFR 191.03 Subpart A

Sat. = Satisfactory NA = Not 

Applicable 

40 CFR 191.03 Compliance Standard EPA Citation Comment (Objective 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) Executive 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 that 

this 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 included 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 groundwater 

surveillance, 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. 
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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 annual 

NESHAP 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 pathway. 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 9x105

cm3

/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 “continuously 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 demonstrate 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 alternative 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 

page 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 continuously 

sampled, 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 demonstrate 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. The 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 Reviewed
Documents Reviewed and Copies Received 

During Inspection

191.03 Subpart A Inspection May 2011

Citation Document Title Subject Matter 

Legal and Technical Reference Documents

EPA 402-R-97-001 Guidance 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. EPA 402-R-97-001, January 1997

"WIPP Subpart A Guidance," 

A-92-56, II-C-2 Memorandum of understanding between EPA and DOE, 

September 29, 1994

Agreement states that although not required, DOE will implement NESHAPs Subpart H regulations at the WIPsite until closure.

DOE/WIPP 93-043 Effects of Salt Loading and Flow Blockage on the WIPP 

Shrouded Probe, by Chandra, Ortiz, McFarland, August 1993, DOE/WIPP 93-043

Report discusses the impact of salt loading on shrouded probe performance.

DOE/WIPP 89-027 Evaluation Of The Station B Effluent Monitoring System 

In The Underground Exhaust Ventilation System At The WIPP, Sept 1990, DOE/WIPP 89-027

Documents testing at WIPP to evaluate the ability of Station B to collect representative samples.

EEG-60 The Influence of Salt Aerosol On Alpha Radiation 

Detection By WIPP Continuous Air Monitors, by Bartlett and Walker, Jan 1996, EEG-60, DOE/AL/58309-60

Reports impact of salt deposits on monitor efficiency. 

DOE/WIPP 89-026 Evaluation Of The Station A Effluent Monitoring System 

In The Underground Exhaust Ventilation System At The WIPP, DOE/WIPP 89-026, Sept 1990

Documents testing at WIPP to evaluate the ability of Station A to collect representative samples.

Rodgers et al., 1994 Single Point Aerosol Sampling: Evaluation of Mixing and 

Probe Performance In A Nuclear Stack, by Rodgers, Fairchild, Wood, Ortiz, Muyshondt, McFarland, July 1994

Compares performance of ANSI isokinetic with shroudprobes at DOE faculties.

PNL-10816 Generic Air Sampler Probe Test, by Glissmeyer and 

Ligotke, Nov 1995, PNL-10816

Test of isokinetic and shrouded probes at Hanford. Tesshow that shrouded probes deliver samples with significantly less particle-size bias.

 PNL-10148 Functional Requirements Document For Measuring 

Emissions Of Airborne Radioactive Materials, by Glissmeyer, Alvarez, Hoover, McFarland, Newton, Rodgers, Nov 1994, PNL-10148

States general functional requirements for system and procedures for measuring emissions.
Documents Reviewed and Copies Received 

During Inspection

191.03 Subpart A Inspection May 2011

Citation Document Title Subject Matter 

PNL-SA-25532 Changing Methodology For Measuring Airborne 

Radioactivity Discharges From Nuclear Facilities, by Glissmeyer and Ligotke, May 1995, PNL-SA-25532

Tests show single-point sampling (shrouded) probes are superior to ANSI style multiple-point probes.

Nichols, 1994 EPA Shrouded Probe Approval. Letter from Mary Nichols 

to Raymond Pelletier, dated November 21, 1994.

Allows DOE to use the shrouded probe as an alternative measuring procedure.

LA-12612-MS Single-Point Representative Sampling with Shrouded 

Probes by McFarland and Rodgers, LA-12612-MS, August 1993

Describes shrouded probe testing requirements and test performed to qualify probe for use at WIPP.

McFarland, 1993 Air Sampling With Shrouded Probes At The WIPP Site, by 

McFarland, Sept 1993

Paper discussing the use of the shrouded probe at WIPPBenefits of the shrouded probe are discussed.

DOE Procedural Documents

WP 12-2, Rev 15 WIPP ALARA Program Manual, WP 12-2, Revision 15, 

06/03/10

Describes organization and responsibilities of ALARA committee and coordinator. 

12-RL.01, Revision 17 Radiochemistry Quality Assurance Plan, 12-RL.01, 

Revision 17, 04/06/11

Describes the management policy and organizational structure, and QA requirement for radiochemical analys

DOE/WIPP 00-3121, Revision 3

Implementation Plan for 40 CFR 191, Subpart A DOE/WIPP 00-3121, Revision 3, January 2010

Outlines program at WIPP to show compliance with 40 CFR 191, Subpart A. 

DOE/WIPP 09-2225 Waste Isolation Pilot Plant Annual Site Environmental 

Report for 2009, DOE/WIPP 09-2225, September 2010

Results of the environmental monitoring program, in 

particular radiological measurements. 

DOE/WIPP 97-2238 Periodic Confirmatory Measurement Protocol for the 

Waste Isolation Pilot Plant, DOE/WIPP 97-2238, Revision 8, August 2008

Used to explain the protocol used to perform periodic confirmatory measurements. 

DOE/WIPP 99-2194, Rev 5

Waste Isolation Pilot Plant Environmental Monitoring Plan. DOE/WIPP 99-219, Rev 5, December 2010. 

DOE environmental monitoring plans at the WIPP site. 

particular interest: Section 4.0, Dose Calculations, and 5

Environmental Monitoring Program.

DOE/WIPP 99-3119, Rev 6

Compliance Monitoring Implementation Plan for 40 CFR 194.14(b), Assurance Requirement, DOE/WIPP 99-3119, Rev 6, 05/10

Outlines monitoring activities at WIPP to demonstrate compliance with 40 CFR 191 and 40 CFR 194.

DOE/WIPP-06-3174 Rev 0, 03/06

WIPP RH Waste Documented Safety Analysis, Section 3.4.1.4. DOE/WIPP-06-3174 Rev 0, 03/06

This selection verifies that the air pathway is the only 

pathway of concern at the WIPP for RH waste.
Documents Reviewed and Copies Received 

During Inspection

191.03 Subpart A Inspection May 2011

Citation Document Title Subject Matter 

DOE/WIPP-95-2065 Rev. 10, 11/06

WIPP CH Waste Documented Safety Analysis, Section 3.4.1.4. DOE/WIPP-95-2065 Rev. 10, 11/06

This selection verifies that the air pathway is the only 

pathway of concern at the WIPP for CH waste. 

IC041072, Rev 9 Calibration of Effluent Monitoring Skids A1, A2, A3, B1 

and B2 Flow Instrumentation, Maintenance Procedure, IC041072, Revision 9 

Instructions for calibration of FAS skids A1, A2, A3, Band B2 flow instrumentation. 

IC041097, Rev 2 Calibration of Station C Flow Instrumentation, 

Maintenance Procedure IC041097, Revision 2

Instructions for calibration of Station C flow instrumentation. 

IC041098, Revision 5 U/G Exhaust Mass Flow Measurement System for Fans 

700A, B & C, Maintenance Procedure, IC041098, Revision 5

Documents calibration verification test and alignment oU/G exhaust. 

IC413000, Revision 5 Station B Mass Flow Measurement System, Loop 

41A001W2001, Maintenance Procedure, IC413000, Revision 5

Documents calibration of Station B mass flow measurement system. 

PM364001, Revision 1 Predictive Maintenance to Determine Station A Probe Pull 

Frequency, Maintenance Procedure PM364001, Revision 1

Determine recommended frequency of Station A probe inspections based on meteorological data.

PM364005, Revision 10

Inspection and Cleaning of Station “A” Sample Probes Bldg. 364, Maintenance Procedure, PM364005, Revision 10

Documents steps to inspect and clean Station A probes. Section 8.3 notes that salt buildup "at the probe inlet should be no more than 2/3 of the area" and "blocking tshroud exhaust should be limited to no more than 1/3 of 

that area".

RES 11-579-a, -b, -c Annual Periodic Confirmatory Measurement Compliance 

Report for the DOE WIPP for Calendar Year 2010, submitted 6/28/2011

Annual NESHAP report. Includes cover letter, report, aCAP88-PC Version 3.0 output file. Documents annual results.

WP 12-ER4903, Rev 14 Radiological Event Response, Emergency Response 

Procedure, WP 12-ER4903, Revision 14, 7/19/10

Procedure documents actions to be taken by CMRO, FSand Radcon if a potential or actual radioactive release ta

place. 

WP 12-ER4916 Consequence Assessment Dose Projection, Technical 

Procedure, Rev 16, 4/7/11

Procedure for estimating the potential dose consequencfrom a release or suspected release of radioactive materusing Hotspot, NARAC, or hand calculations. 
Documents Reviewed and Copies Received 

During Inspection

191.03 Subpart A Inspection May 2011

Citation Document Title Subject Matter 

WP 12-ER4916 Consequence Assessment Dose Projection, Technical 

Procedure WP 12-ER4916, Revision 15, 11/16/09

Documents procedure for estimating the potential dose consequence from a release or suspected release of radioactive material. Reviewed for consistency with Rev.16

WP 12-ER4916, Revision 13

Consequence Assessment Dose Projection, Technical Procedure WP 12-ER4916, Revision 13, 06/24/09

Documents procedure for estimating the potential dose consequence from a release or suspected release of radioactive material. 

WP 12-HP1305, Rev 9 Fixed Air Monitoring Equipment, Technical Procedure 

WP 12-HP1305, Revision 9, 07/06/10

Instructions for the operation of fixed air monitoring equipment. Attachment 2 documents flow rates and alaset points.

WP 12-HP1306, Rev 8 Canberra Alpha Sentry Continuous Air Monitor, Technical 

Procedure WP 12-HP1306, Revision 8, 3/21/10

Instructions for operating the Canberra continuous air monitor equipment at waste revieving bays. Includes dcheck sheets.

WP 12-HP1307, Rev 10 Portable Instrument and Portal Monitor Operability 

Checks, Technical Procedure, WP 12-HP1307, Revision 10, 05/14/09

Instructions for operational checks of portable contamination instruments. 

WP 12-HP1308, Revision 4

Portable Alpha-6 Continuous Air Monitors, Technical Procedure WP 12-HP1308, Revision 4, 3/28/11

Instructions for operation of Portable Alpha-6 continuouair monitor. 

WP 12-HP1500 Radiological Posting and Access Control

WP 12-HP3500, Revision 18

Airborne Radioactivity - Technical Procedure WP 12-HP3500, Revision 18, 05/07/10

Technical procedure. Provides instructions for analyzinreporting, and trending results of air samples. Att. 5 contains Guide for Station A Filter Counting for Re-Eninto the U/G. 

WP 12-HP3700, Rev 4 Radiological Event Reporting, Management Control 

Procedure WP 12-HP3700, Revision 4, 8/18/10

Documents the first estimate of a possible release. 

WP 12-HP4000, Revision 6

Emergency Radiological Control Responses, Emergency and Alarm Response Procedure, WP 12-HP4000, Revision 6, 05/27/10

Addresses radiological contamination events which reqan immediate stop work order.

WP 12-RC.01, Rev 9 Quality Assurance Program Plan for Sampling Emissions 

of Radionuclides to the Ambient Air at the Waste Isolation Pilot Plant, WP 12-RC.01, Revision 9, 04/26/10

QA program for sampling air emissions at WIPP. Contains useful background information regarding the design and qualification of sampling systems at StationD. 
Documents Reviewed and Copies Received 

During Inspection

191.03 Subpart A Inspection May 2011

Citation Document Title Subject Matter 

WP 12-RE3002, Rev 3 Radiological Engineering Off-site Air Sampling - 

Technical Procedure WP 12-RE3002, Revision 3, 12/13/10

Instructions for collecting and documenting Low-Volumfilter retrieval in response to a potential release. 

WP 12-RE3003, Revision 4

Radiological Release of Potentially Contaminated Materials, Waste, and Items - Management Control Procedure, WP 12-RE3003, Revision 4, 10/27/09

Instructions for evaluating materials, waste, and items which are to be released from the WIPP as non-radioactmaterial. 

WP 12-RE3004, Rev 3 Periodic Confirmatory Sampling, Reporting, and 

Compliance Activities, Management Control Procedure, WP 12-RE3004, Rev 3, 11/12/09

This procedure provides instructions for Radiological Engineers of the Radiological Controls Department to fulfill the requirements of NESHAPs. 

WP 12-RL1001 Sample Tracking and Custody, Technical Procedure, WP 

12-RL1001, Revision 9, 02/11/09

Instructions for documenting receipt and storage of samples in WIPP laboratory.

WP 12-RL1002, Rev 9 Alpha Spectroscopy System Operation, Technical 

Procedure, WP 12-RL1002, Revision 9, 10/05/09

Direction for calibrating and operating the Canberra AlpSpectroscopy System as interfaced with the Genie 2000

WP 12-RL1008, Rev 7 Establishing Gross Alpha and Gross Beta Self-Absorption 

Curves, Technical Procedure, WP 12-RL1008, Revision 7, 11/17/09

Instructions for preparing samples of known activity anknown weight to generate self-absorption curves for eacof the gas proportional counters.

WP 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, 10/22/07

Guidance for rapidly performing a variety of screening matrices for both high and low activity Radionuclides.

WP 12-RL1010, Rev 10 Sample Preparation, Technical Procedure, WP 12-RL1010, 

Revision 10, 7/22/10

Directions for preparing samples to determine activity oradionuclides.

WP 12-RL1011, Rev 11 Elemental Separation - Strontium 90, Technical Procedure, 

WP 12-RL1011, Revision 11, 09/13/07

Directions for performing elemental separation of strontium from samples.

WP 12-RL1012, Rev 8 Elemental Separation - Transuranic Products, Technical 

Procedure, WP 12-RL1012, Revision 8, 10/31/06

Describes method for elemental separation and purificaof actinide isotopes in samples.

WP 12-RL1013, Rev 7 Sample Mounting, Technical Procedure, WP 12-RL1013, 

Revision 7, 09/12/07

Directions for electrodeposition sample mounting and neodymium fluoride coprecipitation sample mounting oactinides in preparation for alpha spectroscopy counting

WP 12-RL1014, Rev 6 Routine Laboratory Operations, Technical Procedure, WP 

12-RL1014, Revision 6, 11/05/08

Instructions for routine laboratory operation. 
Documents Reviewed and Copies Received 

During Inspection

191.03 Subpart A Inspection May 2011

Citation Document Title Subject Matter 

WP 12-RL1015, Rev 16 Canberra Alpha Analyst System Operation, Technical 

Procedure, WP 12-RL1015, Revision 16, 9/09/10

Directions for calibrating and operating the Canberra Alpha Analyst 32-chamber alpha spectroscopy system.

WP 12-RL1016, Rev Operation of the Oxford Series 5 Gas Proportional 

Counter, Technical Procedure, WP 12-RL1016, Revision 11, 8/31/10

Guidance for the operation of the Oxford Series 5 Gas Proportional Counter. Editoial changes and instructionfor a power outage made since 2010 inspection

WP 12-RL1200, Revision 0

Plutonium-241 Analysis, Technical Procedure, WP 12-RL1200, Revision 0, 11/26/03

Provides method for the analysis of Pu 241 in any matriafter preparation of the sample in accordance with WP RL1012 and WP 12-RL1015.

WP 12-RL1400, Rev 9 Radiochemistry Laboratory Waste Management, Technical 

Procedure, WP 12-RL1400, Revision 9, 04/02/09

Instructions for handling, management, and disposal of laboratory waste.

WP 12-RL1550, Revision 11

Control of Radioactive Standards, Technical Procedure, WP 12-RL1550, Revision 11, 10/22/09

Instructions for labeling, maintaining inventory, dilution standards, completing standard logbook for new standarreceived, expired standards, depleted standards, and recertification or standards. 

WP 12-RL3002, Revision 8

Radiochemistry Laboratory Data Validation and Verification, Technical Procedure, WP 12-RL3002, Revision 8, 8/27/2010

Instructions for performing radiochemistry analytical daverification and validation by radiochemistry staff.

WP 12-RL3003, Rev. 8 Data Reduction and Reporting, Technical Procedure, WP 

12-RL3003, Revision 8, 2/7/11

Instructions for processing laboratory data from the timsample receipt to the reporting of final results.

WP 13-1, Rev 30 Washington TRU Solutions LLC Quality Assurance 

Program Description, WP 13-1, Revision 30, 11/15/10

Identifies Federal and industry quality standards, and sestandards for WIPP QA programs.

WP12-5, Rev 13 WIPP Radiation Safety Manual, WP12-5, Rev 13, 05/20/10 States radiological control policy and practices, defines 

dosimetry terms.

WP12-EM1012 Airborne Particulate Sampling, Rev 9, 06/07/07 Provides steps for environmental monitoring personnel 

install and collect air filters and maintain records.

WP12-HP2001, Rev 4 Abnormal Radiological Conditions, WP12-HP2001, Rev 4, 

06/24/09

Instructions for radiological control technicians when responding to abnormal conditions.

WP12-HP3000, Rev 15 Radiological Control Administration, WP12-HP3000, Rev 

15, 11/11/10

Instructions for performing radiological control. 
Documents Reviewed and Copies Received 

During Inspection

191.03 Subpart A Inspection May 2011

Citation Document Title Subject Matter 

WP12-HP3200, Rev 12 Radioactive Material Control, WP12-HP3200, Rev 12, 

4/04/11

Instructions for controlling radioactive items 

WP12-HP3300, Rev 2 Radiation Exposure Control, WP12-HP3300, Rev 2, 

08/17/05

Guidance for keeping radiation exposure ALARA. 

WP12-HP3400, Rev 8 Contamination Control, WP12-HP3400, Rev 8, 02/20/09 Management Control Procedure. Guidance and forms f

radiological surveys and decontamination.

Documents Generated During Inspection

JPW-20110510-01 Underground Escape Map, effective date 3/2/2011 Marked with locations of inspection activities JPW-20110510-02 WP 12-ER4916, Attachment 1 - Dose Projection SCompleted during 5/10 accidental release drill JPW-20110510-03 Hotspot Output Table, generated 5/10/2011 JPW-20110510-04 NARAC Report, generated 5/10/2011 JPW-20110510-05 NARAC Plot of Total Effective Dose Equivalent JPW-20110511-06 Station D1 calibration report, 3/21/2011 JPW-20110511-07 Photographs and pixel counts of Station A shroud occlusion, 5/10/2011, 5 pp. JPW-20110511-08 Convergence graph S2750-W0093 JPW-20110511-09 Convergence graph E300-S2180 JPW-20110511-10 Extensiometer graph 51X-GE-00389, W390-S3480 JPW-20110511-11 DIGILEV output file, 3pp.