### DOCKET NO: A-98-49
Item: II-B3-111



## 2009 - Subpart A Inspection Report

INSPECTION No. EPA-WIPP-7.09-14a
OF THE
WASTE ISOLATION PILOT PLANT July 14 to July 16, 2009

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

September 2009

### Table of Contents

1.0 Executive Summary .................................................................................................................. 1

2.0 Inspection Scope ....................................................................................................................... 1

3.0 Inspection Team, Observer s, and Participants .......................................................................... 2

4.0 Performance of the Inspection .................................................................................................. 2

5.0 Summary of Findings................................................................................................................ 6

Attachments

Attachment A Inspection Plan and Checklist

Attachment B Documents Reviewed

### 1 1.0 Executive Summary

The U.S. Environmental Protection Agency (EPA) conducted an annua l inspection of the Department of Energy’s (DOE) Waste Isolation P ilot Plant (WIPP) July 14 to July 16, 2009, as part of our continued oversigh t program. This inspection wa s conducted under the authority of 40 CFR 191, Subpart A. The purpose of this inspec tion 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. Once again this year, EP A reexamined DOE’s continued moisture problems and salt loading at the Station A sampling location in the air exhaust shaft. However, consistent weekly shrouded probe pulls and replacement with cl ean probes appear to mitigate this concern. Since DOE started weekly probe pulls, none of the probes of record—A2 or A3—have failed inspection. DOE has committed to weekly probe pulls and cleaning until a reasonable solution is developed at Station A. EPA inspectors ex amined WIPP’s emission control devices and

methods used to estimate radiation doses to the public. In additi on, the Agency inspected radiation sample locations and equipment, samp le processing, and reviewed the computational methods used to estimate dose. This year EPA was able to observe filt er changes, probe pulls, and probe replacement at Station A and filter changes at Station B.

EPA found that DOE has continued to improve its air monitoring program during the past year, and responded aggressively and appropriate ly to Station A issues. Moisture and salt loading continues to challenge the Station A sa mpling location. The Agency verified that DOE continues to maintain a weekly probe cleani ng frequency and continued to work toward a solution to this persistent problem. DOE con tinues to have an effective radiation sampling program because of the continued diligence of s ite staff, and can calculate both yearly and accidental dose estimates adequately. EPA had one observation, discussed in Section 5 below, as a result of this inspection.

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.

During this inspection the Agency focused on the impact of moisture and salt loading on the sampling location at Station A and the effect iveness of the RADOS continuous air monitors (CAMs) used at the air exha ust of the active waste empl acement panel in the underground.

### 2 3.0 Inspection Team, Observers, and Participants

The inspection team consisted of four EPA st aff. Thomas Kesterson of the New Mexico Environmental Department (NME D) observed the inspection.

Inspection Team Member Position Affiliation

Chuck Byrum Inspection Leader EPA

Nick Stone Inspector EPA

Tom Peake Inspector EPA

Jonathan Walsh Inspector EPA

Numerous DOE staff and contractors participated in the inspection; below is a partial list.

Participant or Observer Participant or Observer

Bob Wade Art Chavez

Joel Siegel Glenn Galloway

Randy Elmore Larry Madl

Mansour Akbarzadeh Dave Speed

Linda Frank-Supka Tom Goff

Dave Kump Ed Flynn

Dan Ferguson David Squires

Jennifer Hendrickson Stewart Jones

4.0 Performance of the Inspection

The inspection began on Tuesday, July 14, 2009, with an opening meeting that included presentations on changes in air monitoring a nd WIPP laboratory activities (COB-M2008-I4 and - I6). Site staff discussed changes in the progr am since the last EPA inspection in July 2008. These presentations included the fo llowing changes to the program:

- Validation of a new procedure that may be able to predict shrouded probe performance, salt loading, and direct when probes should be clean ed/changed. Until this technique is proven, if possible, probe pull frequency will be maintained on a weekly schedule.

- New transport lines have been received. Th ey should be installed by the end of summer 2009.

### 3 - The new probe back flush system, used to flush water from the surface to clean salt accumulation from the probes in-situ, development continues. The testing phase is expected to take up to twelve or more months and the b ackup A-1 probe will be used for this testing.

- Procedures for both effluent monitoring and la boratory analysis have had minor changes.

- The underground RADOS CAMs have had a nu mber of recent changes (COB-A2009-S24 and COB-A2009-S34). A few are listed: -The filter changing mechanism was slowed down to prevent jamming. -Filter jamming was added as a malfunction alarm. -A database for alarms only was added.

-A Master/Slave connection was added to prevent CAMs in one location from changing

filters at the same time.

The EPA inspector observed va rious activities to verify effective implementation of procedures. EPA reviewed procedures and implem entation of procedures, interviewed site staff,

and observed activities such as filt er changes and probe exchanges.

4.1 Overall Inspection Activities

The inspector observed sample filter changes and probe pulls at Stations A, examined the weekly shrouded probe changes, reviewed th e underground RADOS CAMs, and followed the steps taken to process samples at the radiochemistry laboratory.

4.2 RADOS CAMs - Filter Transport Problems

One of the major advantages of the RADOS continuous air monitors (CAMs) at the air exhaust drift of the operating waste emplacemen t panel(s) (presently panel five in the underground) is that when a filter potentially beco mes covered with salt dust due to underground operations the RADOS CAM has a mechanism to automa tically change the filter to a clean filter. During the inspection Tom Kesterson (NMED) reported, followed up by an email COB-A2009- S25 in Attachment B, that peri odically the filter transport “truck” mechanism freezes or jams and

causes the RADOS to malfunction requiring technician interventi on. (Figure 1: RADOS Filter Transport Mechanism, Alpha Spectrum Screen, and RADOS Operation Screen)

### 4 As noted in Section 4.0 above, see COB-A2009-S 24, DOE/WIPP has attempted to mitigate this issue by slowing down the automatic change mechan ism, requiring an alarm-that will be noted at the Central Monitoring Room (CMR ) requiring more effective res ponse, and logging an alarms only database to capture these events. Also to assure continued air sampling in the underground,

the two RADOS CAMs are now connected in a MASTER/SLAVE configuration. This configuration means that both R ADOS CAMs are not allowed to change filters simultaneously. In addition, improved staff training, change filt er cleaning, and filter re placement procedures have been implemented. These changes shoul d mitigate this “freezing” issue and ensure continuous sample of air from the opera ting waste panel (see COB-M2009-S34).

Continuous sampling at this location is very important. This is the first stage in the defense in depth at WIPP. The RADOS CAM notif ies the CMR of an alarm and forces the mine air exhaust to go into HEPA filtration in the ev ent of a potential radioactive release at the air exhaust drift. Therefore, continuous operation of the RADOS is paramount in the earliest detection of potential releases.

One other change to the RADOS CAMs discusse d by site staff that may be significant is the ability to examine all aspects of RADOS CAM operation remotely at a computer terminal on the surface. DOE/WIPP is in the process of inst alling the ability to examine the RADOS operations and spectrum computer screens remote ly via the WIPP network system. This will give emergency response staff the ability to get a “first look” at a po tential release and to estimate the potential source term of a release without having to go underground to examine the RADOS CAMs or reterive the sample filters.

4.3 Continued Moisture Problems and Salt Buildup at Station A

Salt buildup on shrouded probes at Station A c ontinues to be a challenging problem. As noted in last year’s Subpart A annual inspection report, the shr ouded probes of record—Stations A2 and A3—failed in July 2008. Since that time DOE/WIPP has been replacing the probes weekly with clean probes. This appears to ha ve operationally solved the periodic issue of excessive salt build up on the probes. DOE has committed to continue weekly probe pulls and replacing them with clean probes. EPA concurs w ith this approach. (Fi gure 2: Crane Step Up for Probe Pull, Shrouded Probe A-1 as Found, and Probe A-1 Waistline and Inlet)

DOE/WIPP is also examining other solutions to the salt buildup problems. As noted in Section 4.0 above, DOE/WIPP is work ing on testing a back flush system to clean probes in place in real-time. They have also ordered new probe s that may not become salt loaded as easily. Once again, the WIPP staff has continued to be aggr essive and proactive in dealing with Station

A issues.

EPA suggested during the inspection that DOE /WIPP explore the use of Station D as a potential replacement to Station A. EPA was able to make this suggestion because of recent changes to the RADOS CAMs. Station D is locat ed at the bottom of the WIPP air exhaust shaft and presently samples only the air flow pathwa y from the waste emplacement mine drifts.

### 5 Leading up to this inspection, the Agency ha d two major objections to using Station D to replace or augment Station A. First, all air exha ust flow pathways are required to be sampled to ensure representative samples are captured from th e facilities air exhaust. Presently, Station D only samples one of three pathways that culminate at the base of the WIPP air exhaust shaft – the waste receiving area at the base of the wast e handling shaft air flow, the waste emplacement panel air flow, and the experime ntal air flow pathways. Sec ond, how would sample filters be collected at Station D if a poten tial release event did occur so that the source term could be determined? As experienced during the drum punctu re event last year, the mine is evacuated and reentry is strictly controlled during an accident. Therefore, accurately characterizing a potential release source term may be difficult if Stati on D was the primary sampling location with the current measurement configuration.

As a result, EPA believes two things need to take place before Station D can be used as the sampling location of record for Subpart A. First, DOE/WIPP needs to work out how to sample all of the potential release pathways at Station D and to qualify the sampler(s) according to the requirements of EPA’s shrouded probe approval letter (COB-A200 6-3). Secondly, the potential use of RADOS CAMs at St ation D must be evaluated, since this allows the notification

of the CMR in the event of a captured release, switching automa tically to HEPA filtration, and the added ability of integrating the RADOS CAMs remotely to get a direct first estimate of the release source term. Therefore, EPA’s sec ond major concern may be adequately solved.

4.4 Other Inspection Activities

EPA observed filter changes and probe exchanges at Stations A and verified appropriate implementation of site procedures. The EPA inspector also examined the underground RADOS CAM in Panel 5. The Agency also reviewed the accidental release calcul ations performed using the computer code HOTSPOT. These calculations are performed in the event of a potential

### 6 radioactive release. They in clude source term estimation, pres ent weather conditions, and an inceasingly accurate estimate of the potential release source term (from first estimate to actual laboratory measurement). HOTSP OT calculations estimate the potential dose to the public and are used to guide response d ecision making at the site.

EPA also toured the WIPP radiochemistry la boratory. Lab staff dem onstrated the various steps taken to process all kinds of samples; sample filters, soil, and samples of opportunity (i.e, road kill) (COB-A2009-L0 to –L10). The staff clearly showed the documentation produced and

the elaborate effort taken to ensure that the chain of custody is maintained at all times. (Figure 3: Fish Sample Digestion, Column Separation and Alpha Spectrum St eps) EPA found all activities consistent with established procedures.

5.0 Summary of Findings

EPA concludes that DOE adequately implem ents a radiological monitoring and sampling program for WIPP disposal operations and appr opriately performs calculations to estimate potential releases to the public. Tom Kesterson, as noted in Section 4.2 above, documented that the filter transport mechanism of the RADO S CAM may periodically jam and the CAM may malfunction as a result. It appears to EPA that the steps taken by the site noted in Section 4.2 may have mitigated the problem. However, beca use of the importance of this sampling system, the Agency believes that DOE/WIPP should assure th at these issues have been fully resolved. EPA had one observation – the DOE/WIPP document, “Implementation Plan for 40 CFR 191, Subpart A, DOE/WIPP 00-3121 pages 4 and 12 (COB -A2009-A) states that the computer code GXQ is used for accidental release dose calculations. This code has been replaced by the computer code HOTSPOT. This needs to be corrected.

### 7 Attachment A: Inspection Plan and Checklist



## WIPP Inspection Plan - 40 CFR 191, Subpart A for the year 2009

Purpose : EPA will verify that the Department of Ener gy (DOE) has been monitoring and calculating possible radiation doses to members of the public due to normal operations and any accidental releases which may have occurred during the la st 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 op erational phase of mana gement and storage of radioactive waste, comply with th e limits expressed in 40 CFR 191.03.

Scope : The scope of this inspection activity is to veri fy that DOE at WIPP can measure and calculate and has measured and calculated any actual or pot ential radiation dose to members of the public during management and storage of radioactive wa ste during the past year of site operation. Inspection activities will include an examination of the description of monitoring and sampling equipment both on and off site, and in the underground.

The specific purpose of this inspection is to ve rify and confirm that DOE at WIPP has complied with the “Compliance reporting” expectations of EPA 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. In part icular the EPA wishes to verify that DOE complies with the Subpart A standard is demons trated by showing that the annual radiation dose to any member of the public in the genera l environment falls below the regulatory limits.

Focal Areas for this Years Inspection:

# What has changed in air sampling si nce last year’s inspection?

# During past years a number of potential change s were discussed, such as new methods to evaluate salt build-up on Station A probes. What is the status of these activities?

# With continued moisture in the exhaust shaft ai r flow, what have been the conditions of the sample filters? Have the filters had salt bu ildup or samples washed off as in the past?

# Verify that the underground CAMs operate as expected.

# Station A continues to have challenging salt buildup. A pro cedure has been developed by the site that is used to predict probe pu ll/cleaning frequency. Describe how this procedure was developed and specifically how it will be implemented. What testing has been done to verify the accuracy of this procedure?

# How are composite samples handled and processed, measurement accuracy, and implications of laborat ory standards used?

# With the continued challenge of salt buildup at Station A, has testing been done to fully qualify the Shrouded Probe under these conditions as required by EPA’s approval letter?

# Provide a presentation of the process and proc edures used to calcula te off-normal potential release during operations, use flow charts, photographs, etc as needed. Provide examples

### 8 of various accidental scenarios with appropr iate calculations-source term estimates, etc. Describe the process from st art to finish, the steps ta ken to respond to off-normal

situations?

# Bottom-line: If required, how would DOE prove to independent examiners that samples

taken at Station A are re presentative samples?

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 : The 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.

Expected Dates : Week of July 13, 2009.

Information Requested: Before the inspection, provide the most recent annual Safety Analysis Report, information that describes how measur ements are taken, and complete documentation that shows how compliance calculations are pe rformed with an explanation of all input parameters and their derivation a nd all pertinent related to Subpa rt A requirements. Provide documentation and procedures related to subpart Subpart A compliance ac tivities as in past

years.

### 9 # CHECKLIST QUESTION July 2009 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: (1) Discharges of radioac tive material and direct radiation from such management and storage and (2) all operations covered by Pa rt 190; shall not exceed 25 millirems to the whole body, 75 millirems to the thyroid, and 25 millirems to any other critical organ.” 40 CFR 191.03(a) 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? EPA 402-R97-001 Section 2.3, Page 4 The Annual Site Environmental Report for 2007 (DOE/WIPP 08-2225:COB-A2009-C) Executive Summary documents the results of DOE’s efforts to

consider all activities th at impact compliance.
Section 4.9 demonstrates that measured releases are well below the 40 CFR 191.03(b) release standards for a member of the public residing year round at the

fence line. Sat.

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?

[ NOTE: DOE/WIPP 00-3121 reference GXQ as the accidental release computer code, it should

be HOTSPOT. ] EPA 402-R97-001 Section 2.3, Page 5 Section 3.0 of the Implem entation Plan for Subpart A (DOE/WIPP 00-3121:COB-A2009-A), documents the plan to show how this requirement is examined. QAPP for Sampling Emissions (WP 12- RC.01:COB-A2009-F), documents the QA requirements for the sampling of emissions. Annual NESHAP report (COB-A2009-Ja,-Jb,-Jc)

demonstrates that normal operations are examined. CH Waste Documented Safety Analysis (DOE/WIPP 95-2065:COB-A2009-G) and RH Waste DSA (DOE/WIPP 06-3174:COB-A2009-H) documents DOE’s review of potential accidents at WIPP. Procedure Emergenc y Radiological Control Response (WP 12-HP4000:COB-A2009-K) and Consequence Assessment Dose Projection (WP 12- ER4916:COB-A2009-R) documents radiological emergency response activities. Sat.

Media considered in determining compliance

3 Does DOE demonstrate that the air pathway is the credible release pathway? EPA 402-R-97-

001 Section 2.4, Page 5 DOE/WIPP 08-2225 pages xxii, Dose From Air Emission, and 4.1 and DOE/WIPP 00-

3121 Section 2.1 documen ts that the air pathway is the only credible release pathway. 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 DOE/WIPP 08-2225, Section 4.8.4 and Sections 2.1 and 3.5 of Implementation Plan for Subpart A (DOE/WIPP 00-3121) documents the detailed plan for measuring these potential exposure mechanisms. Annual NESHAP report (COB-A2009-Ja,-Jb,-Jc) demonstrates that these exposure mechanisms are

included. Sat.

### 10 # CHECKLIST QUESTION July 2009 40 CFR 191.03 Subpart A

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-R-97-001 Section 2.4, Page 5 and page 6. Section 2.1 of the Implementation Plan for Subpart A (DOE/WIPP 00- 3121:COB-A2009-A) explains DOE’s plan to fulfill this requirement. Annual Site Environmental Report (DOE/WIPP 08-2225:COB-A2009-C) Chapter 4 demonstrates that DOE implements groundwater surveillance, biota sampling and off-site air monitoring programs. 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-R-97-001 Section 2.5, Page 6.

EPA 402-R-97-001 Section 2.5, Page 7 Section 3.1 of DOE/WIPP 00-3121

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.) EPA 402-R-97-001 Section 2.6.1, Page

8 For Subpart A DOE (DOE/WIPP 08- 2225, Section 4.8.4.3) assumes that themember of the public resides, “... yearround at the fence line in the northwest

sector.” DOE/WIPP 08-2225 Section 1.3.2 and the Annual NESHAP report (COB-A2009-Ja,-Jb,-Jc) demonstrate

that DOE considers doses at appropriate offsite points, such as Smith Ranch located 7.5 km away in

the WNW sector. 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-R-97-001 Section 2.6.1, Page

8 For Subpart A DOE (DOE/WIPP 08-2225, Section 4.8.4.3) assumes that the member of the public resides, “... year-round at the

fence line in the northwest sector.” DOE/WIPP 08-2225, Section 1.3.2 and the Annual NESHAP report (COB-A2009-Jb, page 5) demonstrate that DOE considers doses at appropriate offsite points, such as Smith Ranch located 7.5 km away in the

NW sector of WIPP. Sat.

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-R-97-001 Section 2.6.1, Page

8 For Subpart A DOE (DOE/WIPP 08-2225, Section 4.8.4.3) assumes that the member of the public resides, “... year-round at the

fence line in the northwest sector.”

DOE/WIPP 08-2225:COB-A2009-C
Section 1.3.2 and the Annual NESHAP report (COB-A2009-Jb, page 5)

demonstrate that DOE considers doses at appropriate offsite points, such as Smith Ranch located 7.5 km away in the WNW

sector of WIPP

. Sat.

### 11 # CHECKLIST QUESTION July 2009 40 CFR 191.03 Subpart A

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-R-97-001 Section 2.6.2, Page

8 Section 3.2 of the Implementation Plan for Subpart A (DOE/WIPP 00- 3121:COB-A2009-A) describes the “reference man” parameters as described in the CAP88-PC computer code. Annual NESHAP report (COB-A2009-Jc, page 14)

demonstrates that “reference man” is
used to evaluate radiation dose. Sat.

Calculation of dose - Modeling –

Parameters

11 Does DOE provide both whole body

radiation dose and cri tical organ radiation dose for the maximally exposed individual (or a hypothetical indi vidual conservatively located at a point of higher exposure)? EPA 402-R-97-001 Section 2.7.1, Page

8 Annual NESHAP report (COBA2009-Jc, page 3) demonstrates that DOE appropriately fulfills this requirement. Sat.

12 Does DOE calculate radiation doses including all release points and reflecting evaluation of all exposure pathways? EPA 402-R-97-001 Section 2.7.1, Page

8 Section 2.1 of DOE/WIPP 00-3121 states that the air pathway is the most credible but other exposure pathways are monitored. Annual NESHAP report (COB-A2009-Ja,-Jb,-Jc) 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-R-97-001 Section 2.7.2, Page

9 Section 3.2 of DOE/WIPP 00-3121 states that a computer model will be used to

calculate radiat ion doses. Annual NESHAP report demonstrates that DOE is using computer modeling. Sat

14 Does DOE use CAP88-PC to perform

dose calculations? EPA 402-R-97-001 Section 2.7.2, Page

9 DOE/WIPP 08-2225, page xxii and

Section 3.2 of DOE/WIPP 00-3121 states

that CAP88-PC is used for dose calculations. Annual NESHAP report demonstrates that DOE is using CAP88-

PC. Sat.

15 Does DOE use an alternate model for calculating radiation doses? If so, does DOE justify such usage? EPA 402-R-97-001 Section 2.7.2, Page

10 DOE uses a atmospheric dispersion code (HOTSPOT) to determine concentrations
for accidental releases. WP 12-ER4916 (COB-A2009-R) states that HOTSPOT is

used for accidental release calculations. COB-A2009-S11 shows an example of dose projection using the HOTSPOT

code. HOTSPOT is a reasonable choice

for these calculations. Sat.

16 Does DOE adequately supported exposure parameters used in dose

calculations? EPA 402-R-97-001 Section 2.7.3, Page

10 Annual NESHAP repor t demonstrates that DOE is using appropriate parameters

in dose calc ulations. Sat.

### 12 # CHECKLIST QUESTION July 2009 40 CFR 191.03 Subpart A

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-R-97-001 Section 2.7.3, Page

10 Section 3.2 of DOE-WIPP 00-3121 (COB-A2009-A) documents that DOE is using conservative assumptions. Annual NESHAP report (COB-A2009-Ja,-Jb,-Jc) demonstrates that DOE is using conservative simplifying assumptions in dose calculations. Sat.

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 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-R-97-001 Section 2.7.3, Page

10 Section 3.2 of the Implementation Plan for Subpart A (DOE/WIPP 00-3121:COB-A2009-A) states that DOE is using these values as exposure parameters. The Annual NESHAP report (COB-A2009-Jc, page 15) demonstrates that DOE is using these parameters in dose

calculations Sat.

### 13 # CHECKLIST QUESTION July 2009 40 CFR 191.03 Subpart A

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-R-97-001 Section 3.1, Page 11, (1(i)) QAPP For Sampling Emissions (WP 12-RC.01:COB-A2009-F)
Section 4.1 documents that this requirement is appropriately implemented at WIPP. Sat.

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-R-97-001 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-R-97-001 Section 3.1, Page 11, (1(iii)) Implementation Plan for Subpart A(DOE/WIPP 00-3121:COBA2009-A) Section 3.3.1 states that

DOE uses continuous air monitoring at WIPP and does not need to consider this requirement. 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-R-97-001 Section 3.1, Page 11, (2(i)) DOE uses 40 CFR 61 Appendix B

Method 114. WP 12-RC.01
documents in Section 4.2 and

Attachment 1 the location of sampling sites. Sat.

### 14 # CHECKLIST QUESTION July 2009 40 CFR 191.03 Subpart A

Emissions and Environmental Monitoring - Air EPA Citation Comments (Objective Evidence) Result

23a Does DOE demonstrate that radionuclides to be directly monitored or extracted, collected and measured continuously with an in-line detector capable of distinguish relevant radionuclides? As an acceptable alternative to

direct radiation monito ring, the effluent air stream may be 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 uses periodic monitoring at WIPP to show compliance with 40 CFR 191 Subpart A. The Implementati on Plan for Subpart A (DOE/WIPP 00-3121:COB-A2009-A)
Section 3.3.3 states th at DOE uses periodic confirmatory monitoring. DOE/WIPP 00-

3121 Sections 3.5 and 3.3.5 document

relevant radionuclides at WIPP. Annual NESHAP report (COB-A2009-Ja,-Jb,-Jc)

demonstrates that these radionuclides are

monitored. NA

23b 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....” The WIPP is a batch (continuous) process disposing of radioactive waste therefore continuous sample is appropriate. EPA 402-R97-001 Section 3.1, Page 11, (2(ii)) Environmental Monitoring Plan (DOE/WIPP 99-2194:COB-A2009-1)
Section 5.2.1 and DOE/WIPP 00-
3121:COB-A2009-A Section 3.3.2 states that sample sites will acquire representative samples. 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 approve the method

used? EPA 402-R97-001 Section 3.1, Page 12, (2(iii)) The QAPP for Sampling Emissions (WP 12-RC.01:COB-A2 009-F) Section

1.0 documents that DOE used these principles. Sat

25 If DOE is using the “Shrouded Probe”,

does DOE demonstrate that this alternative method is being used according to the guid ance 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, A-98-49,II-B3-12, EPA Approval letter (COB 191AAO-2000: COB-A2006-3) documents

DOE’s evaluation of the Shrouded Probe and its compliance with the EPA criteria. Single Point Representative Sampling withShrouded Probes (LA-12612-MS:COBA2006-4) documents how the shrouded probe was qualified for use at WIPP. Sat.

### 15 # CHECKLIST QUESTION July 2009 40 CFR 191.03 Subpart A

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, Method 114 of 40

CFR Part 61? EPA 402-R-97-001

Section 3.1, Page 12, (2(iv)) QAPP for Sampling Emissions (WP 12-RC.01:COB-A2009-F) Section 1.0 documents DOE quality assurance requirements. These meet the requirements of 40 CFR 61. Implementation Plan for Subpart A (DOE/WIPP 00-3121:COB-A2009-A)
Section 4.0 states that DOE implements NQA requirements which are equivalent to Method 114. 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 underes timate the emissions; (iii) DOE shows the alternative procedure is fully documented; and (iv) DOE has received prior approval from

EPA. EPA 402-R-97-001 Section 3.1, Page 12, (3(i) to 3(iv)) See question #19, DOE usesSection 3.1 (1)(i) of EPA 402-R97-001 page 11. NA.

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-R-97-001 Section 3.1, Page 12 and page 13, (4(i)) Section 3.3.3 of DOE/WIPP 00-

3121 documents DOE’s compliance with this requirement. 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-R-97-001 Section 3.1, Page 13, (4(i)) Section 3.3 of DOE/WIPP 00-3121 documents DOE’s compliance with this requirement. Section 2.0 of the Periodic Confirmatory

Measurement Protocol(DOE/WIPP 97-2238:COBA2009-B) discusse s release points measured confirm compliance with this requirement. Sat.

### 16 # CHECKLIST QUESTION July 2009 40 CFR 191.03 Subpart A

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-R-97-001 Section 3.1, Page 13, (4(i)) DOE uses the shrouded sampling probe as an alternative method. EPA has approved this alternative method (COB-A2006-3) 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 veri fy the low emissions? EPA 402-R-97-001 Section 3.1, Page 13, (4(i)) DOE does not have other release points which have a potential to

release radionuclides. CH(DOE/WIPP-95-2065:COBA2009-G) and RH (DOE/WIPP06-3174:COB-A2009-H) Waste Documented Safety Analysis

documents 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-R-97-001 Section 3.1, Page 13, (4(ii)) Section 2.0 of the Periodic Confirmatory Measurement Protocol (DOE/WIPP-97- 2238:COB-A2009-B) documents
this evaluation and that WIPP has three release points. NA

33 Does DOE demonstrate that 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-R-97-001 Section 3.1, Page 13, (4(ii)) Section 5.2.4 of the WIPP Environmental Monitoring Plan (DOE/WPP 99-2194:COB-A2009- 1) states: “Station A exhausts unfiltered air from the underground repository to the atmosphere. Station B samples HEPA filtered exhaust air from the underground repository to the atmosphere when in Filtration Mode of operation. Station C samples HEPA filtered

exhaust air from the Waste Handling Building to the atmosphere.” Stations B and C uses pollution control equipment,

therefore item 33 is not fulfilled. However, because of the nature of these sample locations and that they are filtered continuously this approach is appropriate; therefore the Agency agrees that DOE’s sample methods are adequate. Sat.

### 17 # CHECKLIST QUESTION July 2009 40 CFR 191.03 Subpart A

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-R-97-001 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-R-97-001 Section 3.1, Page 13, (5(i)) 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-R-97-001 Section 3.1, Page 13, (5(ii)) 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-R-97-001 Section 3.1, Page 13, (5(iii)) 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-R-97-001 Section 3.1, Page 13, (5(iv)) NA

### 18 # CHECKLIST QUESTION July 2009 40 CFR 191.03 Subpart A

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-R-97-001 Section 3.1, Page 13, (5(v)) DOE has not requested approval to

use environmental measurements. NA

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-R-97-001 Section 3.2, Page

14. Implementation Plan for Subpart A(DOE/WIPP 00-3121:COBA2009-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 offsite radiological air monitoring program.” Annual Site Environmental Report (DOE-WIPP 08-2225:COB-A2009-C) Chapter 4

demonstrates that DOE’s environmental program monitors other release points and critical receptor locations. Sat.

### 19 # CHECKLIST QUESTION July 2009 40 CFR 191.03 Subpart A

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-R-97-001 Section 4.2, Page

15. Section 5.0 of the Implementation Plan for Subpart A (DOE/WIPP 00- 3121:COB-A2009-A) documents that DOE’s plans to report results yearly. The Annual NESHAP (COB-A2009- Ja,-Jb,-Jc) report demonstrates that DOE reports results yearly and “...fall below regulatory limits”. Sat.

42 Does DOE report results of monitoring

and the dose calculations for each reporting period? EPA 402-R-97-001 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. 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-R-97-001 Section 4.2, Page

15 Section 5.0 of DOE/WIPP 00-3121 documents that DOE’s plans to report results yearly. The Annual NESHAP Report demonstrates that DOE reports results of monitoring activities and dose is calculated yearly. 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-R-97-001 Section 4.3, Page

16. Section 5.0 of DOE/WIPP 00- 3121 documents that DOE’s plans to report results yearly. The Annual NESHAP Report, page 6, demonstrates that DOE reports planned construction and modification during the year. Sat.

45 Does DOE demonstrate that advanced

notification was not ne eded 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-R-97-001 Section 4.3, Page 16 and page 17. Section 5.0 of DOE/WIPP 00-
3121:COB-A2009-A documents that DOE’s plans to report results yearly. The Annual NESHAP Report, page 6, demonstrates that DOE reports planned construction and modification during the year. 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-R-97-001 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.

### 20 Attachment B

Table of Documents Reviewed