**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**- 2 -** 

### 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 - 3 -** 



### 1.0 Executive Summary

**The U.S. Environmental Protection Agency (EPA) con ducted 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 purp ose 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 D OE 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 p resentations 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 con tractor, Westinghouse TRU Solution**  **(WTS), has an effective radiation sampling program and can calculate doses estimates**  **adequately related to RH waste handling and process ing. The program has adequate**  **documentation/procedures governing the program.**



### 2.0 Scope

**The scope of this inspection was to verify that WI PP is able to measure and calculate the**  **radiation dose to members of the public upon receip t of RH waste for disposal at WIPP.**  **Inspection activities included an examination of th e description of the monitoring and sampling**  **equipment both on and off site, and in the undergro und. This inspection was conducted under**  **the authority of 40 CFR 191, Subpart A and 40 CFR 1 94.21.** 

**EPA also verified that DOE’s “description of any e missions control devices used to limit**  **releases of radionuclides” were adequate in prepara tion 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. - 4 -** 



### 3.0 Inspection Team, Observers, and Participants

**The inspection team consisted of representatives o f 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 par ticipate 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** **- 5 -**



### 4.0 Performance of the Inspection

**The inspection began on Tuesday, January 9, 2007, w ith a presentation by DOE Carlsbad**  **Field Office (CBFO) and WTS on the present status o f the WIPP radiation monitoring program.**  **The inspection team toured and reviewed various act ivities to verify effective implementation of**  **the plan and procedures. The EPA inspection team r eviewed the WIPP quality assurance and**  **waste handling procedures, the location of air samp lers, modeling analysis of estimated doses,**  **and general site environmental monitoring. The ins pectors focused on what, if any, changes had**  **been made to the air monitoring program conducted f or the contact-handled (CH) waste due to**  **RH waste receipt and handling.**

**The inspection team toured and reviewed in more det ail various aspects of the radiation**  **compliance program after DOE/WTS completed the open ing presentations. The inspection team**  **walked through the steps of receiving waste and exa mined the location of samplers in the RH**  **bay of the waste handling building (WHB). Site sta ff 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 discus sed emergency procedures and how releases**  **would be measured if any take place. The inspector s also examined the various steps taken to**  **unload the RH 72-B shipping container and prepare t his waste for emplacement underground. In**  **particular the inspectors looked for potential radi oactive 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 u nderground air samplers at the air**  **exhaust bulkhead of Room 1, Panel 4 and other locat ions 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 wast e processing in preparation for this**  **inspection. The questions and DOE responses are do cumented in COB-RH2007-B2. EPA’s**  **main focus was: what changes have been made in sit e 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, an d 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 po rtion 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 processi ng step and the potential for radioactive**  **contamination to become airborne. (On the map Red d ots = continuous air monitor (CAM) and** **- 6 -**

**area radiation monitor (ARM); Blue dots= CAM only; show approximately locations only)**  **(COB-RH2007-J.) DOE’s sampler placement and equipm ent 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 t he Waste Handling Building **Equipment Type Location**  **CAM (CAM measures alpha and beta) Transfer Cell CAM and ARM (ARM measures gamma radiation) Cask Pre**  **paration 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 Sta tion C on the air exhaust side of the**  **WHB HEPA filters that operate all the time. Air fl ow is controlled in the WHB building by**  **differential pressure to limit any potential radioa ctive releases during RH waste processing.** 



### 4.3 Samplers in the Underground

**DOE will have a number of samplers along the air f low pathway in the underground as**  **CH waste is placed in one room and RH waste is plac ed in an adjacent room. DOE presently**  **places air samplers at the air exhaust of the activ e 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 wil l 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 b ase of the air exhaust shaft, which samples air**  **from the waste processing air circuit just before a ir exits up the air exhaust shaft. EPA agrees** **- 7 -**

**that moving samplers to the air exhaust of the acti ve 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 n ormally sampled at Station A at the**  **top of the air exhaust shaft. If an event takes pl ace, such as if a potential radioactive release wer**  **e 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 H**  **EPA air filters on the surface and exhausted through the air sampler at Station B. Station B sa**  **mples only filtered air and verifies that no release is taking place. This framework is the sam**  **e 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, t he steps used to estimate a release have not**  **changed. - 8 -** 



### 5.0 Summary of findings, observations, concerns, an d recommendations.

**EPA performed this inspection to verify that DOE h as implemented a radiological**  **monitoring and sampling program at the WIPP that wi ll appropriately respond to the introduction**  **of RH waste disposal at WIPP. During this inspecti on the inspectors did not identify any**  **findings or concerns with monitoring program. EPA determines that DOE has adequately**  **implemented the programs and appropriately performe d 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, me asure, and calculate possible releases of** 

**radioactive material from either CH or RH waste at WIPP.** **- 9 -** 

### Attachment A.1

40 CFR 191.03 Subpart A - RH Startup Inspection Pla n

Purpose **: Verify that the Department of Energy (DOE) can d emonstrate that the Waste Isolation**  **Pilot Plant (WIPP) will be able to monitor radiatio n doses to members of the public due to**  **normal operations and any unplanned or accidental r eleases which occur during the reporting**  **periods while emplacing RH waste. The specific pur pose 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 ins pection is conducted under the authority of**  **40 CFR 191, Subpart A and 40 CFR 194.21. This inspe ction is part of EPA’s continued**  **oversight to ensure that WIPP can, during the opera tional 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 i s 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 o f the description, siting, and capability of**  **monitoring and sampling equipment both on and off s ite, and in the underground and waste**  **handling building as it relates to the receipt, pro cessing, handling and emplacing RH waste.** 

**In particular the EPA will verify that DOE’s “descr iption of any emissions control devices used**  **to limit releases of radionuclides” are being in pr eparation 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” h as been developed, documented, and modeled**  **correctly.**

Location **: This inspection will be held at the WIPP facilit y located twenty-six miles south east**  **of Carlsbad, New Mexico and the surrounding vicinit y 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, 20 07.** 

Opening Meeting: **Please describe the processing and emplacement of R H waste. This should**  **include how the program has been modified to deal w ith changes related with RH waste, and link**  **this discussion to appropriate documents and proced ures.** **- 10 -** 

### Attachment A.2

40 CFR 191.03

Inspection

Check List**- 11 -**

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-R**

**97-001**

**Section 4.1, Page** 

**14 Letter: 11/08/06**  **November 8, 2007 letter (COB RH2007-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-R**

**97-001**

**Section 4.1, Page** 

**14 CRA Chapters** 

**1 and 3 CRA Chapter 3, Table 3-1 (COB** 

**RH2007-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-R**

**97-001**

**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-R**

**97-001**

**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 - 12 -** 

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-R**

**97-001**

**Section 4.1, Page** 

**14 DOE-WIPP 06-3174,** 

**WIPP RH DSA (COB RH2007-G), CCA** **Appendix EMP (COB RH2007-F), and**  **Response to EPA questions (COB**  **RH2007-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-R**

**97-001**

**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 (COB**  **RH2007-H). The WIPP Annual Site Environmental Report (COB**  **RH2007-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-R**

**97-001**

**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** **- 13 -** 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 (COB RH2007-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. COB** 

**RH2007-4b1 shows how the WIPP laboratory responses to events. COB** 

**RH2007-4b2 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** **- 14 -** 

### Attachment B

Documents

Reviewed