Docket No: A-98-49, II-B3-101 

Subpart A Inspection Report 

(40 CFR 191.03) 

* RH Startup Inspection * 

January 9-11, 2007 

U.S. Environmental Protection Agency 

Radiation Protection Division 

Washington, DC 20460 

February 2007
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Table of Contents 

Page

1.0 Executive Summary 3 

2.0 Scope 3 

3.0 Inspection Team, Observers, and Participants 4 

4.0 Performance of the inspection 5 

 4.1 Changes to Sampling Due to RH Waste 5 

 4.2 Sampler Locations in RH WHB 5 

 4.3 Samplers in the Underground 6 

 4.4 Underground Air Exhaust Samplers 7 

 4.5 Calculating the Impact of Accidental Releases 7 

 

5.0 Summary of findings, observation, concerns, and recommendations 8 

 

Attachments

Attachment A.1 Inspection Plan 

Attachment A.2 Inspection Checklist 

Attachment B. Documents Reviewed 
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1.0 Executive Summary

 The U.S. Environmental Protection Agency (EPA) conducted an inspection of the 

Department of Energy’s (DOE) Waste Isolation Pilot Plant (WIPP) during January 9-11, 2007 as 

part of its continuing oversight program. The purpose of this inspection was to verify that DOE 

continues to show compliance with the dose release standard found at 40 CFR 191.03, Subpart A 

upon receipt of remote-handled (RH) waste. 

 In particular, the Agency wanted to confirm that DOE would be able to effectively 

monitor radiation releases to members of the public due to both normal operation and any 

unplanned or accidental releases which occur during reporting periods. The inspection examined 

the WIPP’s emission control devices and the methods used to estimate radiation doses to the 

public. 

 As part of the inspection, DOE gave EPA detailed presentations and tours of radiation 

sample locations and equipment, sample processing, and the computational methods used to 

estimate doses. 

 The EPA inspectors found that DOE, through its contractor, Westinghouse TRU Solution 

(WTS), has an effective radiation sampling program and can calculate doses estimates 

adequately related to RH waste handling and processing. The program has adequate 

documentation/procedures governing the program. 

2.0 Scope

 The scope of this inspection was to verify that WIPP is able to measure and calculate the 

radiation dose to members of the public upon receipt of RH waste for disposal at WIPP. 

Inspection activities included an examination of the description of the monitoring and sampling 

equipment both on and off site, and in the underground. This inspection was conducted under 

the authority of 40 CFR 191, Subpart A and 40 CFR 194.21. 

 EPA also verified that DOE’s “description of any emissions control devices used to limit 

releases of radionuclides” were adequate in preparation for receipt of RH waste and are being 

implemented as described and that the approach to “estimate of the radiation doses to which the 

public may be subjected by normal operation of the facility” has been developed, documented, 

and modeled correctly. 

 
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3.0 Inspection Team, Observers, and Participants

 The inspection team consisted of representatives of the EPA Administrator. 

Inspection Team Member Position Affiliation

Chuck Byrum Inspection Team Leader EPA 

Tom Peake Inspector EPA

Shankar Ghose Observer EPA 

 DOE had numerous staff members and contractors participate in the inspection. 

 

DOE/Contractor Participate Affiliation

Mike Oliver DOE/CBFO 

Ernest Preciado DOE/CBFO

Richard Farrell DOE/CBFO

Vernon Daub DOE/CBFO

Don Galbraith DOE/CBFO

Scott Anderson WTS-OPS 

Art Chavez WRES-ECP 

Wille Most WRES-Permitting 

Dave Kump WTS-WWIS 

H.W. Bellows WTS-OPS 

Randy Brittain WTS-OPS 

Subhash Sethi WTS-OPS 

Randy Elmore WTS-IWHE 

Stan Patchet WTS-Mine Eng. 

Linda Frank-Supka WTS-S&H 

Bob Kirby WTS-Underground OPS 

 
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4.0 Performance of the Inspection

 

The inspection began on Tuesday, January 9, 2007, with a presentation by DOE Carlsbad 

Field Office (CBFO) and WTS on the present status of the WIPP radiation monitoring program. 

The inspection team toured and reviewed various activities to verify effective implementation of 

the plan and procedures. The EPA inspection team reviewed the WIPP quality assurance and 

waste handling procedures, the location of air samplers, modeling analysis of estimated doses, 

and general site environmental monitoring. The inspectors focused on what, if any, changes had 

been made to the air monitoring program conducted for the contact-handled (CH) waste due to 

RH waste receipt and handling. 

The inspection team toured and reviewed in more detail various aspects of the radiation 

compliance program after DOE/WTS completed the opening presentations. The inspection team 

walked through the steps of receiving waste and examined the location of samplers in the RH 

bay of the waste handling building (WHB). Site staff discussed sampling procedures in the RH 

Bay while the RH shipping container, the 10-160B or the 72B, is being opened and prepared for 

removal of the waste containers. Site staff discussed emergency procedures and how releases 

would be measured if any take place. The inspectors also examined the various steps taken to 

unload the RH 72-B shipping container and prepare this waste for emplacement underground. In 

particular the inspectors looked for potential radioactive waste release points and the location of 

samplers to assure that potential releases could be appropriately captured. 

 The inspection team then toured and reviewed the underground air samplers at the air 

exhaust bulkhead of Room 1, Panel 4 and other locations of air samplers in the underground. 

Details about inspection activities can be found in Attachment A.2, Inspection Checklist. 

4.1 Changes to Sampling Due to RH Waste 

 EPA asked a number of questions related to RH waste processing in preparation for this 

inspection. The questions and DOE responses are documented in COB-RH2007-B2. EPA’s 

main focus was: what changes have been made in site monitoring because of RH processing, 

and, given any changes how had procedures changed. As noted in DOE’s response, old 

continuous air monitors (CAMs) have been replaced, all potential release locations have been 

evaluated, and DOE evaluated alarm set points. In addition, the Panel 4 radiological monitoring 

will be shifted to the exit of the active panel, and responses to emergency conditions related to 

RH processing have been developed. 

4.2 Sampler Locations in RH WHB 

 EPA examined the location of samplers in the RH portion of the WHB. Figure 1 shows 

the approximate location of some of these samplers. DOE determined the most critical location 

for each sampler based on a review of each processing step and the potential for radioactive 

contamination to become airborne. (On the map Red dots = continuous air monitor (CAM) and 
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area radiation monitor (ARM); Blue dots= CAM only; show approximately locations only) 

(COB-RH2007-J.) DOE’s sampler placement and equipment settings for the RH related 

samplers appear reasonable and appropriate. 

Figure 1. Approximate Location of Samplers in WHB (from COB-RH2007-G, Figure 2.4-6) 

Table 1 Summary of Sampler Locations in RH Bay of the Waste Handling Building

Equipment Type Location 

CAM (CAM measures alpha and beta) Transfer Cell 

CAM and ARM (ARM measures gamma radiation) Cask Preparation Station 

CAM and ARM Facility Cask Loading Room (FCLR) 

CAM and ARM Cask Unloading Room (CUR) 

Air is exhausted from the WHB and is sampled at Station C on the air exhaust side of the 

WHB HEPA filters that operate all the time. Air flow is controlled in the WHB building by 

differential pressure to limit any potential radioactive releases during RH waste processing. 

4.3 Samplers in the Underground 

 DOE will have a number of samplers along the air flow pathway in the underground as 

CH waste is placed in one room and RH waste is placed in an adjacent room. DOE presently 

places air samplers at the air exhaust of the active waste disposal room; this setup will be 

modified when RH is processed in Panel 4. Samplers will be moved to the air exhaust drift of 

the active CH and RH waste panel. Unused rooms will be isolated from the active room air flow 

circuit by special bulkheads (COB-RH2007-BI; Figure 2) to properly direct air flow. DOE may 

also place air samplers at the air exhaust bulkhead of any active room if deemed necessary 

(COB-RH2007-B2, last paragraph of question 1). DOE also has air samplers at other locations 

in the underground, including Station D, near the base of the air exhaust shaft, which samples air 

from the waste processing air circuit just before air exits up the air exhaust shaft. EPA agrees 
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that moving samplers to the air exhaust of the active waste panel is reasonable and appropriate. 

Figure 2. Example Bulkhead in Panel 4 (COB-RH2007-BI) 

4.4 Underground Air Exhaust Samplers 

 Unfiltered air exhausted from the underground is normally sampled at Station A at the 

top of the air exhaust shaft. If an event takes place, such as if a potential radioactive release were 

detected in the underground by an air sampler or a member of the staff, then exhaust air is 

stopped until air flow is redirected to a bank of HEPA air filters on the surface and exhausted 

through the air sampler at Station B. Station B samples only filtered air and verifies that no 

release is taking place. This framework is the same for CH and RH waste. 

4.5 Calculating the Impact of Accidental Releases 

DOE CH dose estimate procedure, WP 12-ER4903, used to calculate potential release in 

the case of possible radioactive releases, has been modified to support RH waste processing at 

WIPP. In particular Attachment 6 – Information of RH Events has been added to define 

parameters unique to RH waste dose determination, the steps used to estimate a release have not 

changed. 
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5.0 Summary of findings, observations, concerns, and recommendations.

 EPA performed this inspection to verify that DOE has implemented a radiological 

monitoring and sampling program at the WIPP that will appropriately respond to the introduction 

of RH waste disposal at WIPP. During this inspection the inspectors did not identify any 

findings or concerns with monitoring program. EPA determines that DOE has adequately 

implemented the programs and appropriately performed the calculations to estimate potential 

releases to the public. EPA believes that changes to the program at WIPP, in response to the 

disposal of RH waste, show that DOE can capture, measure, and calculate possible releases of 

radioactive material from either CH or RH waste at WIPP. 
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Attachment A.1 

40 CFR 191.03 Subpart A - RH Startup Inspection Plan

Purpose: Verify that the Department of Energy (DOE) can demonstrate that the Waste Isolation 

Pilot Plant (WIPP) will be able to monitor radiation doses to members of the public due to 

normal operations and any unplanned or accidental releases which occur during the reporting 

periods while emplacing RH waste. The specific purpose of this inspection is to verify and 

confirm that, for RH waste, WIPP has complied with the “Notification of startup” expectations 

of EPA 402-R-97-001, Section 4.1, page 14. This inspection is conducted under the authority of 

40 CFR 191, Subpart A and 40 CFR 194.21. 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 Section 191.03 Standards. 

Scope: The specific scope of this inspection activity is to verify that WIPP will be ready to 

measure and calculate the radiation dose to members of the public upon receipt of RH waste. 

Inspection activities will include an examination of the description, siting, and capability of 

monitoring and sampling equipment both on and off site, and in the underground and waste 

handling building as it relates to the receipt, processing, handling and emplacing RH waste. 

In particular the EPA will verify that DOE’s “description of any emissions control devices used 

to limit releases of radionuclides” are being in preparation for receipt of RH waste and 

implemented as described and that the “estimate of the radiation doses to which the public may 

be subjected by normal operation of the facility” has been developed, documented, and modeled 

correctly. 

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: The EPA expects to complete its inspection, with DOE’s cooperation, in two days. 

Each day will begin with an opening meeting at 8:00 a.m. and end at 5:00 p.m. with a closeout 

session. 

Date: Expected to be held during the week January 8, 2007. 

Opening Meeting: Please describe the processing and emplacement of RH waste. This should 

include how the program has been modified to deal with changes related with RH waste, and link 

this discussion to appropriate documents and procedures. 
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Attachment A.2

40 CFR 191.03 

Inspection 

Check List 
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Notification of 

Startup 

Expectations

RH Startup Inspection 

January 9, 2007 

# Question EPA 

Citation

Documentation Comments (Objective Evidence) Result

1 Did DOE provide a 

notification of the 

anticipated date of 

initial receipt not 

more than 60 days 

nor less than 30 days 

before the shipment 

date? 

EPA 

402-R97-001 

Section 

4.1, Page 

14 

Letter: 11/08/06 November 8, 2007 letter (COBRH2007-A) satisfies this 

requirement. DOE notified EPA of 

expected RH shipments in January, 

2007.

SAT 

2 Did DOE provide the 

name and location of 

the facility? 

EPA 

402-R97-001 

Section 

4.1, Page 

14 

CRA Chapters 

1 and 3

CRA Chapter 3, Table 3-1 (COBRH2007-D) and Chapter 1, Figure 

1-2 (map) (COB-RH2007-C) 

provides adequate information 

about the name and location of the 

facility. 

SAT 

3 Did DOE provide 

technical information 

describing the size, 

design, and method 

of operation of the 

facility? 

EPA 

402-R97-001 

Section 

4.1, Page 

14 

CRA Chapter 3 CRA Chapter 3, Section 3.0 and 

Figure 3-3 (COB-RH2007-D) 

describes the size, design, and 

method of operation.

SAT 

4 Did DOE provide a 

list of the 

radionuclides 

handled at the 

facility? 

EPA 

402-R97-001 

Section 

4.1, Page 

14 

CRA Chapter 4 CRA Chapter 4 (COB-RH2007-E) 

list RH TRU waste inventory that is 

expected in the RH waste shipped 

to WIPP, see Tables 4-2 and 4-7. 

SAT 
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Notification of 

Startup 

Expectations

RH Startup Inspection 

January 9, 2007 

# Question EPA 

Citation

 Documentation Comments (Objective Evidence) Result

5 Did DOE provide a 

description of any 

emissions control 

devices used to limit 

releases of 

radionuclides? 

EPA 

402-R97-001 

Section 

4.1, Page 

14 

DOE-WIPP 06-3174, 

WIPP RH DSA (COBRH2007-G), CCA 

Appendix EMP (COBRH2007-F), and 

Response to EPA 

questions (COBRH2007-B2) 

DOE-WIPP 06-3174 (COB-RH2007-

G) Sections 2.6.3.2 and 2.6.3.7 

adequately discusses that HEPA 

filtration is used in the waste handling 

building (WHB) (Station C) and will 

be used in the air exhaust shaft exit 

(Stations B) if an accident takes place; 

Station A, as well as numerous 

underground air samplers, sample air 

exhaust continuously during normal 

operations. These sampling locations 

have not changed since the CH startup 

inspection in 1999, DOE has 

reevaluated RH bay sampling 

requirements and updated additional 

sampling locations in the RH bay of 

the WHB, these locations are 

discussed in the DOE’s response to 

EPA questions (COB-RH2007-B2, 

question 1). The inspection team 

toured and reviewed these locations to 

verify this information. 

SAT 

6 Did DOE provide an 

estimate of the 

radiation doses to 

which the public may 

be subjected by 

normal operation of 

the facility? 

EPA 

402-R97-001 

Section 

4.1, Page 

14 

DOE-WIPP 06-3174 

(COB-RH2007-F)

DOE-WIPP 06-3174 (COB-RH2007-

F) DOE’s safety analysis documents 

off-normal operation. The annual 

NESHAPs report documents normal 

operation doses to the public (COBRH2007-H). The WIPP Annual Site 

Environmental Report (COBRH2007-I) on page VIII, “Releases 

and Radiological Dose to the Public” 

also report estimated radiation does to 

the public during normal operations. 

The inspection team will verify the 

calculations used to support this 

conclusion during the annual Subpart 

A inspection in June 2007. 

SAT 

7 Did DOE provide a 

written notification 

of the actual date of 

initial receipt of 

radioactive waste? 

EPA 

402-R97-001 

Section 

4.1, Page 

15 

COB-RH2007-BM January 18, 2007 email from Russ 

Patterson (DOE) announcing that RH 

shipments commenced at 14:53 

(MST) January 18, 2007. 

SAT 
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Subpart A - Accident Reporting Supplemental Checklist 

# Questions Comment (Objective Evidence) Results

 8 Assume the CMR monitors an 

underground CAM alarm at 0900, 

January 9, 2007 while emplacing a RH 

waste canister in the underground. 

Report the steps taken to deal with such 

an event, using reasonable detail - not 

everything that takes place. List major 

steps involved and provide objective 

evidence that verifies the quality of 

results at each step, noting procedures 

used. 

For example: 

-Release notification 

-Taking samples 

-Laboratory measurements 

-Derivation of the source term 

-Calculation of projected doses 

You have four hours to complete this 

task. 

We are looking for how samples are 

collected, analyzed, and how the RH 

dose is calculated/estimated. Show 

various examples. 

In response to this checklist item, site 

staff walked the inspector through a 

sample response. A number of 

simultaneous actions controlled by 

numerous procedures take place 

whenever an event is noted. For 

example, when a Hi-Hi CAM alarm is 

received in the CMR, air flow is 

stopped and exhaust air is diverted to 

HEPA filtration in generally less than 

five minutes (see Section 2.0 WP 12-

HP4903). Generally WP 12-HP4903 

(COB-RH2007-M) guides response 

activities. Other procedures come into 

play. WP 12-ER4902 (COB-RH2007-

P) guides the cleanup. WP 05-

WH4401 (COB-RH2007-BD) guides 

the steps taken by waste handlers. WP 

12-HP4000 (COB-RH2007-N) directs 

concurrent activities to obtaining data 

about possible radioactive materials 

released. WP 12 HP-3700 (COBRH2007-L) is used to direct how 

radiological information is transmitted 

during an event. WP 12-ER3905 

(COB-RH2007-Q) guides the process 

used to categorize an event. WP 12-

ER4916 (COB-RH2007-K) is used to 

estimate dose. 

During this exercise site staff showed 

clearly that they know what to do, 

when, and how. They appeared to be 

well drilled and practiced. COBRH2007-4b1 shows how the WIPP 

laboratory responses to events. COBRH2007-4b2 shows the results of a 

realistic GXQ dose calculation. The 

inspector concluded that site staff are 

prepared to response to RH 

radiological events appropriately. 

SAT 
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Attachment B

Documents 

Reviewed