### 1 DOCKET NO: A-98-49
Item: II-B3-125



## 2012 - Subpart A Inspection Report

INSPECTION No. EPA-WIPP-7.12-17a
OF THE
WASTE ISOLATION PILOT PLANT July 17-19, 2012

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

March 2013

### 2 Table of Contents

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

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

3.0 Inspection Team, Observer s, and Participants ...........................................................................4

4.0 Performance of the Inspection ............................................................................................. ......4

5.0 Summary of Findings ....................................................................................................... ..........7

Attachments

Attachment A Inspection Plan and Checklist

Attachment B Documents Reviewed

### 3 1.0 Executive Summary

The U.S. Environmental Protection Agency (EPA) conducted an annua l inspection of the Department of Energy (DOE) Waste Isolation P ilot Plant (WIPP) from July 17 to 19, 2012 as part of its continued oversight program. This inspection was c onducted under the authority of 40 CFR 191, Subpart A. The purpose of this inspecti on was to verify that DOE was in continued compliance with the dose release sta ndard found at 40 CFR 191.03, Subpart A.

EPA reviewed DOE’s ability to monitor radi oactive releases to the public due to normal waste disposal operations and any unplanned or accidental releases that might occur during disposal operations. EPA inspectors examined WIPP’s emission control devices and methods used to estimate radiation doses to the public . In addition, EPA insp ected radiation sample locations and equipment, sample processing, and reviewed the computational methods used to
estimate dose.

During recent years, EPA has focused heavily on moisture issues and salt occlusion of the sampling probes at Station A, which samp les air leaving the exhaust shaft. DOE has conducted systematic studies of the situation an d responded with regular changes of the probes and update to EPA in the form of photographs a nd probe change reports, and EPA has concluded that Station A is being effectively managed a nd continues to produce re presentative samples.

This year, two off-normal events which took place at the WIPP site were brought to EPA’s attention. In November 2011, a waste pa yload from Oak Ridge National Laboratory required special handling due to minor surface contamination by radon progeny, and in June 2012, a drum from Idaho National Laboratory was punctured by a forklift in the underground. Although the site responded appropriately to each in cident, and neither resu lted in any release of radioactivity, EPA used this annua l inspection to conduct a full revi ew of each incident, and to focus on the site’s ability to respond to and a ssess the consequence of any potential release.

EPA found that site staff responded appropriate ly and according to procedure in each of the two incidents, and that DOE has responde d to staff turnover in the area consequence assessment by conducting training and allowing ne w staff to critique and improve written procedures. EPA verified that site staff and are able to calculate both yearly and accidental dose estimates adequately. DOE continues to increas e probe cleaning frequency as needed and is effectively managing salt occlusion problems at Station A. DOE c ontinues to have an effective radiation sampling program because of this con tinued diligence. 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.

### 4 During this inspection the Agency reviewed the ability of DOE to produce representative samples at Station A, as well as the operation of Station B, Station C, the RADOS CAMs used at the air exhaust of the active waste emplacemen t panel in the underground, and Station D.

EPA also addressed the site’s ability to characterize a radiological release during an emergency, and the tracking of samples and an alytical results thr ough the WIPP laboratory. Reviews of two off-normal events that took place at the site since the last inspection in May 2011 provided objective evidence that th e site is able to respond to an incident, and use sampling and analytical data to determine its extent.

EPA had no findings or concer ns during the inspection.

3.0 Inspection Team, Observers, and Participants

The inspection team consisted of four EPA st aff. Thomas Kesterson of the State of New Mexico Environmental Departme nt observed the inspection.

Inspection Team Member Position Affiliation

Tom Peake Inspection Lead EPA ORIA

Kathleen Economy 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 Participant

Larry Madl Dan Ferguson

Jacqueline Davis Jennifer Hendrickson

Mansour Akbarzadeh David Squires

Adán Peña Jim Flora

4.0 Performance of the Inspection

The inspection began on Tuesday, July 17, 2012, with an opening meeting that included presentations on changes in air monitoring and WI PP laboratory activities. Site staff discussed changes in the program since the last EPA insp ection in May 2011. These presentations included

### 5 the following updates and changes to the program:

- Probe pulls at Station A were conducted with a maximum probe pull in terval of two weeks. There have been no failures of the pr imary probe during the past two years.

- Flow control and backup power upgrades are underway at Station B because the current instrumentation is no longer supported by the manufacturer. Station C was upgraded beginning in January 2011, and has not changed since the la st inspection. No changes have been made recently at Station D.

- Underground RADOS CAMs are operating in th e exhaust drift of Pa nel 6, and are being installed in Panel 7. Software security requ irements, which have delayed planned remote electronic access to underground RADOS CAMs since 2010, have not been resolved. - As a result of staff turnover, new consequen ce assessment engineers are being trained. Input from the trainees has been incorporated in to emergency procedures, specifically 12-ER4916, Consequence Assessment Dose Projection.

- WIPP laboratories reported that in FY2012, no elevated acti vity was observed in any air sample.

The EPA inspection team reviewed procedur es, interviewed site staff, and observed activities to verify the effectiv e implementation of procedures relevant to Subpart A. These
activities are described in detail below.

4.1 Review of Of f-Normal Events

Following the opening meetings on July 17, 201 2, the inspection team met with DOE and site personnel to review the two off-normal in cidents which occurred at the site since the previous inspection. On November 9 and 10, 2011, radiation control (Rad Con) found elevated amounts of surface radioactivity on the exteri or of payload TW112 and the interior of TRUPACT 132, which was shipped from Oak Ridge . Although this was su spected to be the result of the radon gas passing through the drum filters and building up inside the sealed TRUPACT, the site treated the payload as poten tially compromised until additional surveys and laboratory analyses ruled out contamination by transuranic isotopes or fission products. When this determination was made, a procedure wa s developed to emplace the payload without exposing site workers to the small amounts of ra don progeny (specifically lead-210) expected to
remain on its surfaces. The TRUPACT remained s ealed and was returned to Oak Ridge for any decontamination deemed necessary.

On June 12, 2012, AMWTP Drum BN10440928 was punctured by a forklift during normal emplacement activities in Panel 6, Room 5. The incident was immediately reported, the area evacuated, and the underground exhaust shifte d to HEPA filtration mode. A reentry plan was developed, and surveys of the drum surface, the forklift, and the surrounding area showed that there was no radioactivity released by the accident. The drum was sealed and emplacement

### 6 continued.

Air monitoring results confirm that there was no release of radioactivity at WIPP during
either event. EPA finds that site personnel responded quickly, appropriately, and according to procedures during each event. During the July 17 meeting, EPA raised the concern that it was not
notified of the November 10 surface contamin ation incident until December 9, 2011. DOE has demonstrated that no release took place, and therefore is not compelled by the reporting requirements found at 40 CFR §194.4. The Agency believes that during the time frame of November 10-16, when the incident was being treat ed as a potential loss of containment, it would have been appropriate for DOE to notif y EPA of the ongoing situation. DOE management was receptive to this comment.

EPA’s full investigation of each incident may be found at Docket A-98-49, Items II-B3- 123 and II-B3-124, respectively.

4.2 Stations A, B, and C

Station A, which samples unfiltered air ex hausted 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 infl ux of water to the exhaus t shaft. The inspection
team visited Station A on the af ternoon of July 17. Skid A-1 was not in operation, Skid A-3 was the sampler of record, and Skid A-2 was collect ing back-up samples. All flow meters were within calibration, and Skid A-2 was operating co rrectly. Skid A-3 showed a low-flow alarm, which is not uncommon. At EPA’s request, site representatives provide d documentation showing that the alarm was received by the central mon itoring room, and was corrected with a filter change shortly after the inspection te am was at Station A (JPW-20120717-06).

The inspection team visited Station B and Sta tion C to verify calib ration dates and flow rates. At Station B, Skid B-2 was offline for maintenance, and Skid B-1 was calibrated and flow rates were appropriate. At Station C, whic h samples the exhaust from the waste handling building, inspectors observed that the flow me ter’s calibration sticker indicated that it had expired on May 5, 2012. After checking their records, site staff confirmed that the sticker was correct. Due to site-wide delays in procedural updates, the calib ration interval of the new flow meter (installed in 2011) was not reflected in procedure. The in strument remained within a 90- day grace period, and staff submitted a report form to elevate the priority of recalibration and address the procedural issue (JPW-20120717- 08). EPA considers the issue closed.

4.2 Consequence Analysis

On the afternoon of July 17, EPA inspectors me t with Consequence Assessment staff in the Emergency Operations Center. EPA request ed that a consequence assessment drill be conducted for a forklift puncture of a drum at th e active waste face. Site staff used current meteorological data, waste emplacement info rmation, and procedure WP 12-ER4916, Rev. 17 to

### 7 perform the dose calculation us ing HOTSPOT (JPW-20140717-04).

As mentioned earlier in this report, seve ral consequence assessment engineers were recently trained due to staff changes. During the re quested drill, inspectors noted that these staff were knowledgeable and familiar with proce dure WP 12-ER4916, and had contributed to the most recent set of revisions to the procedure. EP A inspectors also reviewed the results of other recent exercises carried out by consequence assessment staff (J PW-20120717-05) as well as the certifications and training reco rds of the staff interviewed.

4.3 Underground Sampling

During the underground tour on July 18, inspecto rs observed the continuous air monitors (CAMs) placed at the exha ust of Panel 6 (the active waste pane l) and Station D, at the bottom of the exhaust shaft. One CAM was tagged out due to an efficiency test failur e, while the other was operating with air flow and pressure differentia ls within the acceptable range. Station D’s calibration sticker was illegible , however, the site was able to produce documentation showing
that the CAM had been r ecalibrated (JPW-20120717-07).

4.4 WIPP Laboratory

EPA also inspected the WIPP laboratory, wh ich supports annual NESHAP reporting and emergency response activities at WIPP. Inspector s toured the laboratory itself and were given a presentation of the laboratory’s an alytical services. This year’s lab visit afforded the inspection team to ask detailed questions about the labo ratory response to the November 10, 2011 discovery
of elevated surface radiation in TRUPACT 132. The laboratory manager presented the inspection team with the data package related to the inci dent (JPW-20120717-09). Inspectors also reviewed QA and chain-of-custody documenta tion for the same set of samples. Samples were correctly processed 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 ac tivities over the past year. DOE and site staff continue to effectively manage monitori ng Station A probe conditi ons. EPA agrees that biweekly probe changes are generally appropriate , and that whenever possible, skids A-2 and A3 should be relied upon as the skid of recor d. EPA inspectors noted that the consequence assessment department has worked diligently thr ough a period of staff changes to maintain its ability to effectively respond to any incident involving th e potential release of radioactive
materials.

The inspection activities served to verify th at DOE is correctly implementing procedures which allow it to accurately monitor and calculate possible radiation doses to members of the public due to WIPP site operation. The insp ection checklist included as Attachment A specifically documents DOE’s compliance with each reporting expectation set forth in EPA’s

### 8 WIPP Subpart A Guidance (402-R-97-001). Based on the inspection activities documented in this report, EPA concludes that DOE conti nues to adequately implement a radiological monitoring and sampling program for WIPP di sposal operations in which it collects representative samples and appropr iately performs calcu lations to estimate potential airborne releases to the public. The results of this program, documented in the Annual Periodic Confirmatory Measurement Compliance Report fo r Calendar Year 2011 (RES 12-522) show that the effective dose equivalent (EDE) value to the maximally exposed individual resulting from normal operations conducted at WIPP is less than 1.75x10 -05 

### millirem (mrem) per year, demonstrating that DOE remains compliant with the dose limits expressed in 40 CFR 191.03(b).

EPA does not have any findings or concerns.

### 9 Attachment A: Inspection Plan and Checklist



## WIPP Inspection Plan - 40 CFR 191, Subpart A for the year 2011 Purpose : EPA will verify that the Department of 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 o ccurred during the last reporting period. This inspection is conducted under the au thority 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 radio active 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 radioact ive waste, specifically during th e past year of site operation. Inspection activities will include an examina tion 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” exp ectations 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: EPA will review any changes that have taken place in air sampling since last year’s inspection. As in past years, EPA will review the status of activiti es taken to monitor and address
moisture in the exhaust shaft and salt occlusi on on Station A probes. Sampling equipment, lab procedures, and off-normal event response will be reviewed, with the goal of demonstrating how, if required, DOE would prove to independent examiners that samples taken at Station A are representative samples.

EPA will additionally conduct a revi ew of the response to two off-normal incidents which have taken place since the last inspection: the id entification of NORM on TP132 in November 2011, and the puncture of AMWTP drum BN10440928 in the underground on June 19, 2012. EPA will review the samples collected (swipes and ai r filters) and analyses performed during each

response.

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

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

### 10 Date : July 17-19, 2011.

Information Requested: EPA has received and is reviewing relevant documentation and procedures related to Subpart A, and will request additional documentation if needed.

### 11 Attachment A Inspection Checklist

# CHECKLIST QUESTION July 2012 40 CFR 191.03 Subpart A

Sat. = Satisfactory NA = Not Applicable

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

Does DOE “...provide reasonable assurance that the combined annual dose equivalent to any member of the public in the general environment resulting from discharges of
radioactive material and direct radiation from such management and storage shall not exceed 25 millirems to the whole body and 75 millirems to any other critical organ.” 40 CFR 191.03(b) 40 CFR 191.03 Subpart A -
Environmental
Standards for Management and Storage DOE has demonstrated that they can capture, measure, and calculate releases to assure that they are and
remain below these limits

. Sat.

Scope of activities considered in determining compliance

1 Does DOE demonstrate that all activities at the WIPP up until the point of disposal are considered in determining compliance? Activities include those at “all WIPP facilities, both at above-ground locations and in the underground disposal system” and those related to “arrival or receipt of waste, inspections of containers, unloading, and waste movement.” EPA 402-R97-001 Section 2.3, Page 4 The Annual Site Environmental Report for 2010 (DOE/WIPP 11- 2225) Execu tive Summary
documents DOE’s efforts to consider all activities that impact compliance. The Annual Periodic Confirmatory Measurement Compliance Report for Calendar Year 2011 (RES 12-522,
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 12- 522) 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 17) document radiological emergency response activities, including an initial assessment of possible dose to the public. Sat.

Media considered in determining compliance

3 Does DOE demonstrate that the air pathway is the credible release pathway? EPA 402-R97-001 Section 2.4, Page 5 Section 2.1 of the Implementation Plan for Subpart A describes the process by which the air pathway was
established as the credible release pathway, and the use of environmental monitoring of other exposure pathways to confirm thatthis remains the case.(DOE/WIPP00-3121, Rev. 3, p.7) Sat.

4 Does DOE demonstrate that other exposure
mechanisms from an air release could include inhalation of contaminated air, immersion in a plume of radioactive particles, ingestion of soil on which contaminated particles have been deposited, swimming in ponds in which radionuclides have been deposited are
considered? EPA 402-R97-001 Section 2.4, Page 5 Sections 2.1 and 3.5 of the Implementation Plan for Subpart A documents methods for measuring these potential exposure pathways (DOE/WIPP 00-3121, Rev. 3).
Section 4.8.4 of the ASER documents
the consideration of dose from these pathways (DOE/WIPP-11-2225). Annual NESHAP report (RES 12- 522) confirms that these exposure
mechanisms are in cluded in dose
calculations. Sat.

### 13 Media considered in determining compliance EPA Citation Comments (Objective Evidence) Result

5 Is DOE monitoring the expected air exhaust pathway and performing environmental monitoring of other release points and exposure pathways to confirm air exhaust as the only release pathway? EPA 402-R97-001 Section 2.4, Page 5 and page 6. Yes. Section 2.1 of the Implementation Plan for Subpart A explains DOE’s plan to fulfill this requirement(DOE/WIPP-00-3121, Rev. 3). Annual Site Environmental Report Chapter 4 demonstrates that DOE implements groundwatersurveillance, biota sampling and offsite air monitoring programs (DOE/WIPP-11-2225). 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-11- 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 11-2225).
The Annual Periodic Confirmatory Measurement Compliance Report for
the DOE WIPP for Calendar Year 2011 (RES 12-522), or “2011 NESHAP Report,” identifies Smith
Ranch as the location of the maximally exposed individual. The nearest farms, dairies, and beef ranching activities are also
considered. Sat.

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

### 14 9 Does DOE “conduct separate analyses of potential dose received from each exposure pathway?”
Then does DOE “assume that a member of the public resides at the single geographic point on
the surface where the maximum dose would be
received?” EPA 402-R97-001 Section 2.6.1, Page 8 Yes. See checklist Item 7. Sat.

Personal parameters EPA Citation Comments (Objective Evidence) Result

10 Does DOE assume that the individual exhibits personal characteristics of the “reference man” when evaluating radiation dose to the maximally exposed individual? EPA 402-R97-001 Section 2.6.2, Page 8 Section 3.2 of the Implementation Plan for Subpart A describes the “reference man” parameters as described in the CAP88-PC computer code (DOE/WIPP 00-3121, Rev. 3). These parameters are confirmed on page 8) of the CAP-88 output file included in the 2011 NESHAP report (RES 12-522-b). 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 2011 annualNESHAP report (RES 12-522, CAP88 output file) Sat.

12 Does DOE calculate radiation doses including all release points and reflecting evaluation of all exposure pathways? EPA 402-R97-001 Section 2.7.1, Page 8 Section 2.1 of DOE/WIPP-00-3121, Rev. 3 states that the air pathway is the most credible, but that other exposure pathways are monitored to confirm the air pa thway. Annual NESHAP report (RES 12-522) 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.
17 states that HOTSPOT is used for
accidental release calculations. During the inspection, EPA requested an example dose projection using HOTSPOT (JPW-20120717-04).
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 12- 522) 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 i ndividual located at a residence, assumed continuous exposure (24 hours per day).

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

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

Assume inhalation rate for air to be 9x10 5

cm 3 /hr.

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

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

Assume ingestion of milk to be 112 liter/yr.

Assume ingestion rate of produce to be 176 kg/yr EPA 402-R97-001 Section 2.7.3, Page 10 DOE uses these exact values as exposure parameters (DOE/WIPP 00- 3121, Rev. 3, Section 3.2). The Annual NESHAP report CAP-88 output file demonstrates that DOE is using these parameters in dose calculations (RES 12-522). 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.

### 18 Emissions and Environmental Monitoring -

Air EPA Citation Comments (Objective Evidence) Result

23

a 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

23
b 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. 9. The procedure Periodic Confirmatory Analysis, Reporting, and Compliance Activities (WP 12-RE3004, Rev. 4) describes the criteria for confirming that a filter sample is representative, and documents how to report and handle a sample which does not meet these requirements. Sat.

24 Does DOE demonstrate that radionuclides are collected and measured using procedures based on the principles of measurement described in Appendix B, Method 114 of 40 CFR 61? If not, does DOE demonstrate that the Administrator has approved the method used? EPA 402-R97-001 Section 3.1, Page 12, (2(iii)) Attachment 1 to the QAPP for Sampling Emissions (WP 12-RC.01, Rev. 9) documents both the requirements of Method 114, and
where WIPP documentation reflects these principles. Sat

### 19 25 If DOE is using the “Shrouded Probe”, does
DOE demonstrate that this alternative method is being used according to the guidance provide in “An Explanation of Particle Sampling in a Moving Gas Stream Within a Duct Using an
Unshrouded and Shrouded Probe”? EPA 402-R97-001 Section 3.1, Page 12, (2(iii)(a)) An Assessment of the WIPP Shrouded Probe Against EPA Approval Criteria for Use of Single Point Sampling with the Shrouded Probe HA:98:0100 (Included in August 2000 Inspection Report, A98-49, II-B3-12, EPA’s Approval letter (Nichols 1994) documents
DOE’s evaluation of the Shrouded Probe and its compliance with the EPA criteria. Single Point Representative Sampling with Shrouded Probes (LA-12612-MS) documents how the shrouded probe was qualified for use at WIPP. Sat.

Emissions and Environmental Monitoring -

Air EPA Citation Comments (Objective Evidence) Result

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

Section 3.1, Page 12, (2(iv)) QAPP for Sampling Emissions (WP 12-RC.01, Rev. 9) Section 1.0 documents DOE quality assurance requirements. These meet the requirements of 40 CFR 61. See
Checklist Item 24. Sat.

27 If it is impractical to measure the effluent flow rate in accordance with the method(s) in Section 3.1(1) or to monitor or sample extraction according to methods in Section 3.1(2) has DOE demonstrated that the use of
alternative effluent flow rate measurement or site selection and sample extraction are appropriate and that the alternate method are used provided the following:

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

EPA. EPA 402-R97-001
Section 3.1(3)(i) to (3)(iv), Page

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

27.

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

### 20 28 Does DOE demonstrate that radionuclide
emission measurements are in conformance with the methods in Section 3.1(1) and (2) to be made at all release points which have a potential to discharge radionuclides into the air in quantities which could cause a combined annual dose equivalent in excess of 1% of the dose limit in Subpart A? EPA 402-R97-001 Section 3.1, Page 12 and

p age 13, (4(i)) DOE/WIPP 00-3121, Rev. 3., Section 3.2 documents DOE’s compliance with this requirement. All areas of a potential discharge are continuouslysampled, although even in a worstcase accident scenario, 1% of the Subpart A dose limit is not expected to be reached. This requirement is
also discussed in Sections 1.0 and 2.0 of DOE/WIPP 97-2238, Rev. 8. Sat.

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

Emissions and Environmental Monitoring -

Air EPA Citation Comments (Objective Evidence) Result

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

31 Does DOE demonstrate that for other release points which have a potential to release radionuclides into the air it has performed periodic confirmatory measurements to verify
the low emissions? EPA 402-R97-001 Section 3.1, Page 13, (4(i)) DOE has no other points with a potential to release radionuclides. CH (DOE/WIPP-95-2065,Rev. 10) and RH (DOE/WIPP-06-3174, Rev. 0) Waste Documented Safety Analysis document these
conclusions. NA

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

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

### 21 Environmental Measurements (Page 1) EPA Citation Comments (Objective Evidence) Result

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

Environmental Measurements (Page 2) EPA Citation Comments (Objective Evidence) Result

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

### 22 Emissions and Environmental Monitoring -
Other Media

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 11- 2225). Sat.

Compliance Reporting EPA Citation Comments (Objective Evidence) Result

41 Does DOE demonstrat e compliance with the Subpart A standard by showing that the annual radiation dose to any member of the public in the general environment falls below the regulatory limits? EPA 402-R97-001 Section 4.2, Page 15. The Annual NESHAP report demonstrates that DOE reports results yearly, and that those results fall below regulatory limits. For calendar year 2010, the calculated effective dose equivalent to the maximally exposed individual of the public was less than 1.75x10 -5
mrem(RES 12-522). Sat.

42 Does DOE report results of monitoring and the dose calculations for each reporting period? EPA 402-R97-001 Section 4.2, Page 15 Section 5.0 of DOE/WIPP 00-3121 documents that DOE’s plans to report
annual results. Th e Annual NESHAP Report demonstrates that DOE reports results of monitoring and dose results yearly – see checklist item 41. Sat.

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

Notification of construc tion 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 2011 (RES 12-522). 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 demonstrate that
documentation is sufficient to allow EPA to verify compliance with Subpart A. Sat.

### 24 Attachment B

Table of Documents Reviewed