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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 2011

 
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Contents 

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

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

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

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

4.1 Monitoring of Geomechanical Parameters ............................................................................ 6 

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

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

Changes in the Culebra Groundwater 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 Them 
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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 (WIPP) 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 inspection report contains the inspection plan 

and the checklist used by the EPA inspectors, and Attachment B lists documents 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 parameter databases, and reviewed documents and 

procedures directing these monitoring activities. 

The EPA found that DOE continues to effectively 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 monitoring programs are reported annually. 

2.0 Scope 

The EPA WIPP Compliance Criteria (40 CFR Part 194.42(a)) require DOE to “conduct an 

analysis of the effects of disposal system parameters 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-closure 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 categories and listed in Table 1. EPA accepted these 

ten monitoring parameters in the 1998 Certification 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 reservoir 
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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 parameter monitoring program at WIPP. Inspection 

activities included an examination of monitoring and sampling equipment both on and off site, 

and in the underground. EPA also reviewed numerous sampling procedures and measurement 

techniques and verified implementation of an effective quality assurance program (see the 

document list in Attachment B of this report). 

 
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3.0 Inspection Team, Observers, and Participants 

The inspection team consisted of five EPA staff listed in Table 1. Others observing the 

inspection were Thomas Kesterson and Julia Marple 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 ORIA 

 
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4.0 Inspection Schedule 

The inspection began on Tuesday, May 10, 2011, with 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 demonstrations 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 field 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 areas to verify continued implementation of the 

DOE parameter monitoring program during the pre-closure phase: 1) written plans and 

procedures, 2) quality assurance procedures and records, and 3) results of the monitoring 

program in the form of raw data, intermediate reports, and final annual reports, if appropriate. 

The inspection checklist in Attachment A provides details of these inspection activities. 

4.1 Monitoring of Geomechanical Parameters 

DOE committed to measure four geomechanical parameters in the CCA: creep closure, extent of 

deformation, initiation of brittle deformation, and displacement of deformation features. These 

parameters are monitored through convergence monitoring, deformation monitoring, fracture 

mapping and stratigraphic and fracture mapping, respectively. WIPP has four programs that 

supply information for these four parameters: the geomechanical monitoring program, the 

geosciences program, the ground control program, and the rock mechanics program. These 

programs are documented in WP 07-1, WIPP Geotechnical Engineering Program Plan. The 

status of geomechanical monitoring procedures, with respect to changes and revisions, is 

provided below. 

 WP 07- EU1301, Manually Acquired Geomechanical 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 Data Processing - Revision 4 (05/03/11) 

 

In addition to reviewing procedures, EPA inspectors examined monitoring and measurement 

techniques, manually and remotely acquired instrument data and the storage, accuracy and 

consistency of the reported data in DOE WIPP Reports. Inspection personnel interviewed WIPP 

geotechnical engineering personnel to discuss any programmatic changes, observed manual 

convergence measurements and fracture mapping, examined data from stratigraphic mapping 

and remotely measured extensiometers, compared staff practices to written procedures, and 

reviewed the annual WIPP Geotechnical Analysis Report for July 2009 to June 2010 

(DOE/WIPP 11-3177, March 2011). 
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EPA met with staff from the WIPP Geotechnical 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 concurrence with the process documented in WP 07-EU1303. The 

measured value was 13 feet and 2 inches from floor to the roof at this point. Underground 

fracture mapping is also an integral part of the 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 inches wide, and are addressed by rock bolting in a 

regular pattern. 

During the afternoon of May 11, inspectors visited 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 measurements that the rate of deformation is consistent 

and predictable. The deformation mechanism remains unchanged and the effects of RH 

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

indicated that with the advancement in mining, the monitoring stations are being relocated. 

Panel 4 is no longer being monitored and the measurements are taken in Panel 5 and 6. 

Instruments are being installed in Panel 7. EPA 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 activities, EPA concluded that the procedures are adequate for proper 

measurements and did not identify any concerns or findings. 

4.2 Monitoring of Hydrological Parameters 

DOE committed to measure two hydrological parameters in the CCA: Culebra groundwater 

composition, and changes in the Culebra groundwater flow direction (as indicated by Culebra 

fresh water heads). Culebra groundwater chemistry and potentiometric head measurements are 

performed by members of the WIPP environmental monitoring program. Programmatic 

functions and responsibilities 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 which the groundwater monitoring program falls 

under. 

Culebra Groundwater Composition 

Changes in the Culebra groundwater composition 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 10th opening presentation (EPA 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. 
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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 11th, the EPA inspector arrived at well WQSP-5. The field team 

consisted of Robin Spoon and Richie Jimenez. Rick Salness also was in attendance. The field 

team was on the third day of taking groundwater serial samples for this well and in the process of 

taking end measurements, collecting final groundwater samples, and packing samples for 

shipment to an offsite laboratory. The EPA inspector observed the field team collecting 

groundwater serial samples and performing total alkalinity, anion/cation balances per the 

following technical procedures: 

Groundwater Serial Sample Analysis (WP 02-EM1005 Rev 7, Inspection ID: KMEM2011-GW11) 

Serial and Final Sample Analysis (WP 02-EM1006 Revision 8, Inspection ID: KMEM2011-GW12) 

The inspector observed the team collecting ‘final’ serial samples 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 Serial 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 out sample documentation and chain of custody 

forms. During this inspection the EPA inspector observed staff following the procedure and 

completing appropriate steps for sample collection, labeling, preservation and documentation. 

The EPA inspector observed the field team measuring groundwater pH, alkalinity 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 titration, 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 pages 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 divalent 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 concentration 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 measured and calculated divalent 

cation concentrations as specified in the procedure. 
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The inspector cross-checked the total iron formula given in procedure Step 9.19, WP 02 EM1005 Revision 7 (Step 9.1.9, page 51) against Excel calculations (EPA Inspection ID: KMEM2011-GW05, Serial Sampling Fe Calc Sheet). The inspector determined that the iron 

concentration formula specified in procedure is accurately represented 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 immersed during repeated rinses. 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 the field team followed and implemented proper 

procedures for testing groundwater chemistry. 

Review of Culebra Groundwater Flow 

During the 2011 inspection, the EPA inspector requested information about changes in the 

program over the past year. In the May 10th opening presentation Rick Salness, (WRES) WIPP’s 

Ground Water Monitoring Program lead staff member, reported the following changes in WIPP 

monitoring wells since the 2010 inspection (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 drilled 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 Inspection 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: COB-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 heads, 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 regional anthropogenic activities affecting the Culebra water table 
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(e.g., mining, drilling, and borehole exploration activities). Of note, the hydrographs in the 2009 

annual report appear to be the same as those given in the 2008 report and this issue was brought 

up in a discussion with Rick Salness. Rick Salness 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 Potentiometric Surface Map for the Annual Site 

Environmental Report and Shallow SubSurface Water (WP 02-EM1025, Revision 2; EPA 

INSPECTION ID: KME-M2011-GW13) which is designated as the default procedure used to 

generate the Culebra potentiometric map for the ASER. 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 Laboratories. 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 the annual ASER document. The procedure 

was reviewed and cross-checked against the potentiometric map and water level elevation data, 

both presented in Figure 6.12 and Table 6.3, respectively, of the ASER report (DOE/WIPP-10-

2225 , Figure 6.12 Model-Generated June 2009 Freshwater Head Contours (5-Foot Contour 

Interval) in the WIPP Vicinity with Blue Water 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 which procedure is used to create the Culebra 

potentiometric map used in the ASER. The review of WP 02-EM1002 and found it to have 

‘dead-end’ directions. While this is not a breach in the monitoring and recording of Culebra 

groundwater flow direction, it is difficult to trace when the steps of this procedure are invoked, 

and clarification of some ‘dead-end’ steps required additional discussion among DOE staff. EPA 

suggests DOE modify procedure WP 02-EM1025 to reflect its actual use, clarify potential deadend directions, and direct the reader to the specific procedure used to generate the annual Culebra 

potentiometric map reported in the ASER. 
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 4.3 Monitoring of Waste 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 violate limits set by the WIPP Land Withdrawal Act and 

the most recent compliant performance assessment. 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 system used to track total activity 

and waste components (e.g., ferrous and non-ferrous metals, organic materials and MgO) 

emplaced in WIPP and is used to generate reports 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 (EPA INSPECTION ID: KME-M2011-

WACT07). DOE reports annual waste activity information and is given in the Annual Change 

Report 2009/2010, Table 3 (DOE/WTS November 15, 2010. EPA INSPECTION ID: KMEM2011-WACT14). 

On May 11, 2011, while in the waste handling room, EPA Inspectors observed RH waste 

container number AE0085 (Figure 1, EPA INSPECTION ID: KME-M2011-WACT07) 

undergoing the remote tracking and scanning process 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-WACT04) indicates RH container 

AE0085 waste was emplaced in the repository on May 12, 2011 as appropriate. 

The WDS system tracking CH/RH waste activity emplaced in the repository was spot-checked. 

Inspectors queried the data base for time periods when waste was received in Panel 4, then cross 

checked this activity with a query bookending this timeframe. EPA 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 consistency 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)
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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 frame. These query reports are listed below: 

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

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

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

The EPA inspector reviewed activities 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 drilling related parameters in the CCA: the drilling rate and the 

probability of encountering a Castile brine reservoir. These parameters are measured as part of 

the Delaware Basin Drilling Surveillance Plan, WP 02-PC.02 Revision 3 (EPA INSPECTION 

ID: KME-M2011–DB08). The surveillance program measures and records many parameters 

related to drilling activities around the WIPP site. The results of the surveillance program are 

documented quarterly and combined 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 using 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 drilling activities was presented during the May 10th, 

2011 opening briefing (EPA Inspection ID: KME-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 inspectors 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 the process to update databases with information 

from various commercial and state sources. Additionally, 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-DB06). During staff interviews and 

demonstrations of the Delaware Basin database, EPA inspectors verified that DOE adequately 

tracks drilling rates and Castile brine encounters near WIPP, and reports results annually and 

quarterly. 

4.5 Monitoring of Subsidence Parameters 

DOE committed to measure surface subsidence at the WIPP site. This parameter is documented 
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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, Section 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 readable 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 adequately and results are reported yearly. 

5.0 Summary of Results 

Based on program documents, interviews, and field demonstrations during the inspection, EPA 

concludes that the monitoring program covers the ten monitoring parameters required by EPA’s 

1998 Certification Decision. This inspection determined that monitoring sample collection, and 

sample/data analysis procedures were complete and appropriate; that staff were adequately 

trained and implemented the procedures adequately; and that appropriate quality assurance 

measures are applied. EPA continues to find that DOE has maintained adequate parameter 

monitoring during the past year and has appropriate procedures and requirements in place. EPA 

has no findings or concerns. 

 
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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 commitments 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 under the authority of 40 CFR 194, Section 21. 

This inspection is part of EPA’s continued oversight to ensure that WIPP can, in fact, monitor 

the performance of significant parameters of the disposal system. 

Scope: 

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

and off site, and in the underground. A review of sampling procedures and measurement 

techniques may be conducted. Quality assurance procedures and documentation for each of 

these activities will also be reviewed. 

Focal Areas of This Year’s Inspection: 

- What has changed in the monitoring program this past year? 

- What documentation and procedures have changes? 

- Update the monitoring program and results for the past year. 

- Have any monitoring parameters changed, and 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 before 5:00 p.m. with a closeout session. 

Expected Date: Week of May 13, 2011. 

Documents For Review: The latest versions of any documentation and/or procedures related to 

the DOE monitoring program. 

 
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2010 Monitoring Inspection Checklist

Checklist for Geotechnical Monitoring 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). 

SAT 
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Checklist for Hydrologic Monitoring 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. 

SAT 

 
18

Checklist for Waste Activity Monitoring 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 09-3427 

Rev 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. 

SAT 
19

Checklist for Drilling Rate Monitoring 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 Rev 

3 (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 calculations, 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. 

SAT 
20

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. 

SAT 

 
21

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 technical 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. 

SAT 

 
22

Attachment B: Documents Reviewed 
Documents Received and Reviewed During Inspection 194.42 Monitoring Inspe

May 2011

EPA Inspection ID# Document Title DOE ID# 

Hydrologic Documents 

KME-M2011-GW09 WIPP Groundwater Monitoring Program Plan WP 02-1 Revision 10 KME-M2011-GW10 WIPP Site Environmental Report for 2009 DOE/WIPP-10-2225 KME-M2011-GW14 Oral Presentation by Rick Salness N/A KME-M2011-GW11 Groundwater Serial Sample Analysis WP 02-EM1005 Rev 7 KME-M2011-GW12 Serial and Final Sample Analysis WP 02-EM1006 Rev 8 KME-M2011-GW3 p. 61, Groundwater Serial Sample Analysis WP 02-EM1005 Rev 7 KME-M2011-GW04 Attachment 7: Serial Sampling Field Laboratory Report for Alkalinity WP 02-EM1005 Rev 7, Att. KME-M2011-GW13

Construction of the Potentiometric Surface Map for the Annual Site Environmental Report and Shallow SubSurface Water WP 02-EM1025, Rev 2

KME-M2011-GW14

Preparation of Culebra Potentiometric Surface Contour Map SNL SP 9-9, Revision 0 Kuhlman, K. 2009. SNL SP 

Monitoring of Waste Activities

KME-M2011-WACT07 WIPP Waste Data System Program and Data Management Plan WP 08-NT.01 Revision 22KME-M2011-WACT14 Annual Change Report 2009/2010, Table 3 KME-M2011-WACT07 Figure 1 - Monitor Picture of RH Canister In Waste Handling Room N/A KME-M2011-WACT04 The database query report N/A KME-M2011-WACT03

WDR - Waste Data System, Emplacment History Overview Report Panel 4 (waste activity query period 01/01/1999 - 12/31/2009) N/A

KME-M2011-WACT01

Waste Isolation Pilot Plant Nuclide Report Generated on May 12, 2011 11.25 AM (Selection Criteria, Start Date: 01/01/1999 End Date: 12/31/2009) N/A

KME-M2011-WACT02

Waste Isolation Pilot Plant Nuclide Report Generated on May 12, 2011 11.28 AM [Selection Criteria, Start Date: 01/01/2009 End Date: 12/31/2009] N/A
KME-M2011-WACT05

Waste Isolation Pilot Plant Nuclide Report Generated on May 12, 2011 11.39 AM [Selection Criteria, Start Date: 01/01/1999 End Date: 05/12/2011] N/A

 KME-M2011-DB02 Delaware Basin Annual Monitoring Report DOE-WIPP-10-2308 KME-M2011-DB11 Delaware Basin Monitoring Quarterly Report N/A 

Delware Basin Documents 

KME-M2011–DB08 Delaware Basin Drilling Surveillance Plan WP 02-PC.02 Rev 3 KME-M2011–DB01 Delaware Basin Monitoring Annual Report, December 2010 DOE/WIPP-10-2308 KME-M2011-DB10 Delaware Basin Drilling Database Upgrade Program WP 02-EC3002 Rev 4 KME-M2011-DB07 DOE presentation: Delaware Basin drilling activities N/A  KME-M2011-DB02 Delaware Basin Annual Monitoring Report DOE-WIPP-10-2308 KME-M2011-DB11 Delaware Basin Monitoring Quarterly Report N/A 

Subsidence Documents 

KME-M2011-SUB03 WIPP Underground and Surface Surveying Program WP 09-ES.01 Rev 5 KME-M2011-SUB01 WIPP Subsidence Monument Leveling Survey 2010 DOE/WIPP 11-2293 KME-M2011-SUB02 Subsidence Survey Data Acquisition Report, WP 09-ES4001, Rev 1 JPW-20110511-11 DIGILEV output file, 3pp.

Geotechnical

N/A

Geotechnical Analysis Report for July 2009 - June 2010, DOE/WIPP 10-3177, Volumes One and Two (Support Data) DOE/WIPP 10-3177, Vol. I 

N/A Manually Acquired Geomechanical Instrumentation Data, Technical 

Procedure, WP 07-EU1301, Revision 6, 03/19/08

WP 07-EU1301 

N/A Geomechanical Instrument Data Processing, Technical Procedure, WP 07-

EU1303, Revision 3, 06/18/08

WP 07-EU1303, Rev 3 

N/A Installing Convergence Reference Points, WP 07-EU1304, Technical 

Procedure, Revision 5, 10/19/09

WP 07-EU1304, Rev 5 

N/A Installing Rock Bolt Load Cells, Technical Procedure, WP 07-EU1306, 

Revision 4, 10/19/09

WP 07-EU1306, Rev 4 

N/A Installing Wire Extensometers, Technical Procedure, WP 07-EU1308, Rev 

2, 10/19/09

WP 07-EU1308, Rev 2 

N/A Geologic and Fracture Mapping Of Facility Horizon Drifts, Technical 

Procedure, WP 07-EU1001, Revision 3, 7/21/10

WP 07-EU1001, Rev 3 

JPW-20110511-08 Convergence graph S2750-W0093 N/A JPW-20110511-09 Convergence graph E300-S2180 N/A JPW-20110511-10 Extensiometer graph 51X-GE-00389, W390-S3480 N/A