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
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 Table of Contents 

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

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

3.0 Inspection Team, Observers, 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 

 

 
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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) from July 17 to 19, 2012 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 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. 

 During recent years, EPA has focused heavily on moisture issues and salt occlusion of 

the sampling probes at Station A, which samples air leaving the exhaust shaft. DOE has 

conducted systematic studies of the situation and responded with regular changes of the probes 

and update to EPA in the form of photographs and probe change reports, and EPA has concluded 

that Station A is being effectively managed and continues to produce representative 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 payload 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 incident, and neither resulted in any release of 

radioactivity, EPA used this annual inspection to conduct a full review of each incident, and to 

focus on the site’s ability to respond to and assess the consequence of any potential release. 

 EPA found that site staff responded appropriately and according to procedure in each of 

the two incidents, and that DOE has responded to staff turnover in the area consequence 

assessment by conducting training and allowing new 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 increase probe cleaning frequency as needed and is 

effectively managing salt occlusion problems at Station A. DOE continues to have an effective 

radiation sampling program because of this continued 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 emplacement 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 analytical results through 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 the site is able to respond to an incident, and use sampling 

and analytical data to determine its extent. 

EPA had no findings or concerns during the inspection. 

3.0 Inspection Team, Observers, and Participants

 The inspection team consisted of four EPA staff. Thomas Kesterson 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 

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 WIPP laboratory activities. Site staff discussed 

changes in the program since the last EPA inspection in May 2011. These presentations included 
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the following updates and changes to the program: 

- Probe pulls at Station A were conducted with a maximum probe pull interval of two weeks. 

There have been no failures of the primary 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 last inspection. No changes have been made 

recently at Station D. 

- Underground RADOS CAMs are operating in the exhaust drift of Panel 6, and are being 

installed in Panel 7. Software security requirements, which have delayed planned remote 

electronic access to underground RADOS CAMs since 2010, have not been resolved. 

- As a result of staff turnover, new consequence assessment engineers are being trained. Input 

from the trainees has been incorporated into emergency procedures, specifically 12-ER4916, 

Consequence Assessment Dose Projection. 

- WIPP laboratories reported that in FY2012, no elevated activity was observed in any air 

sample. 

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

activities to verify the effective implementation of procedures relevant to Subpart A. These 

activities are described in detail below. 

4.1 Review of Off-Normal Events 

 Following the opening meetings on July 17, 2012, the inspection team met with DOE and 

site personnel to review the two off-normal incidents which occurred at the site since the 

previous inspection. On November 9 and 10, 2011, radiation control (RadCon) found elevated 

amounts of surface radioactivity on the exterior of payload TW112 and the interior of 

TRUPACT 132, which was shipped from Oak Ridge. Although this was suspected 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 potentially compromised until additional surveys and 

laboratory analyses ruled out contamination by transuranic isotopes or fission products. When 

this determination was made, a procedure was developed to emplace the payload without 

exposing site workers to the small amounts of radon progeny (specifically lead-210) expected to 

remain on its surfaces. The TRUPACT remained sealed 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 shifted 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 
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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 contamination 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 treated as a potential loss of containment, it 

would have been appropriate for DOE to notify 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 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. The inspection 

team visited Station A on the afternoon of July 17. Skid A-1 was not in operation, Skid A-3 was 

the sampler of record, and Skid A-2 was collecting back-up samples. All flow meters were 

within calibration, and Skid A-2 was operating correctly. Skid A-3 showed a low-flow alarm, 

which is not uncommon. At EPA’s request, site representatives provided documentation showing 

that the alarm was received by the central monitoring room, and was corrected with a filter 

change shortly after the inspection team was at Station A (JPW-20120717-06). 

The inspection team visited Station B and Station C to verify calibration 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, which samples the exhaust from the waste handling 

building, inspectors observed that the flow meter’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 calibration interval of the new flow 

meter (installed in 2011) was not reflected in procedure. The instrument 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 met with Consequence Assessment staff in 

the Emergency Operations Center. EPA requested that a consequence assessment drill be 

conducted for a forklift puncture of a drum at the active waste face. Site staff used current 

meteorological data, waste emplacement information, and procedure WP 12-ER4916, Rev. 17 to 
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perform the dose calculation using HOTSPOT (JPW-20140717-04). 

As mentioned earlier in this report, several consequence assessment engineers were 

recently trained due to staff changes. During the requested drill, inspectors noted that these staff 

were knowledgeable and familiar with procedure WP 12-ER4916, and had contributed to the 

most recent set of revisions to the procedure. EPA inspectors also reviewed the results of other 

recent exercises carried out by consequence assessment staff (JPW-20120717-05) as well as the 

certifications and training records of the staff interviewed. 

4.3 Underground Sampling 

During the underground tour on July 18, inspectors observed the continuous air monitors 

(CAMs) placed at the exhaust of Panel 6 (the active waste panel) and Station D, at the bottom of 

the exhaust shaft. One CAM was tagged out due to an efficiency test failure, while the other was 

operating with air flow and pressure differentials 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 recalibrated (JPW-20120717-07). 

4.4 WIPP Laboratory 

EPA also inspected the WIPP laboratory, which supports annual NESHAP reporting and 

emergency response activities at WIPP. Inspectors toured the laboratory itself and were given a 

presentation of the laboratory’s analytical services. This year’s lab visit afforded the inspection 

team to ask detailed questions about the laboratory 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 incident (JPW-20120717-09). Inspectors 

also reviewed QA and chain-of-custody documentation 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 activities over the past year. DOE and site 

staff continue to effectively manage monitoring Station A probe conditions. 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 record. EPA inspectors noted that the consequence 

assessment department has worked diligently through a period of staff changes to maintain its 

ability to effectively respond to any incident involving the potential release of radioactive 

materials. 

 

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 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 
8

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 airborne 

releases to the public. The results of this program, documented in the Annual Periodic 

Confirmatory Measurement Compliance Report for 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. 
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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: 

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 activities taken to monitor and address 

moisture in the exhaust shaft and salt occlusion 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 review of the response to two off-normal incidents which have 

taken place since the last inspection: the identification 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 air filters) and analyses performed during each 

response. 

Location: This inspection will be held at the WIPP facility 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 before 5:00 p.m. with a closeout session. 
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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. 
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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 (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 2010 (DOE/WIPP 11-

2225) Executive 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 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-11-2225). 

Annual NESHAP report (RES 12-

522) confirms that these exposure 

mechanisms are included 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 groundwater 

surveillance, 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 annual 

NESHAP 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 pathway. 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 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 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 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. 
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 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 1.75x10-5

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. 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 

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