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, Observers, 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 annual inspection of the 

Department of Energy’s (DOE) Waste Isolation Pilot Plant (WIPP) July 14 to July 16, 2009, as 

part of our 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. Once again this year, EPA 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 clean 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 examined WIPP’s emission control devices and 

methods used to estimate radiation doses to the public. In addition, the Agency inspected 

radiation sample locations and equipment, sample processing, and reviewed the computational 

methods used to estimate dose. This year EPA was able to observe filter 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 appropriately to Station A issues. Moisture and salt 

loading continues to challenge the Station A sampling location. The Agency verified that DOE 

continues to maintain a weekly probe cleaning frequency and continued to work toward a 

solution to this persistent problem. DOE continues to have an effective radiation sampling 

program because of the continued diligence of site 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 effectiveness of the RADOS continuous air monitors 

(CAMs) used at the air exhaust of the active waste emplacement panel in the underground. 
2

3.0 Inspection Team, Observers, and Participants

 The inspection team consisted of four EPA staff. Thomas Kesterson of the New Mexico 

Environmental Department (NMED) 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 and WIPP laboratory activities (COB-M2008-I4 and -

I6). Site staff discussed changes in the program since the last EPA inspection in July 2008. 

These presentations included the following 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 cleaned/changed. Until this technique is proven, if 

possible, probe pull frequency will be maintained on a weekly schedule. 

- New transport lines have been received. They 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 backup A-1 probe will be used for this testing. 

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

- The underground RADOS CAMs have had a number 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 various activities to verify effective implementation of 

procedures. EPA reviewed procedures and implementation of procedures, interviewed site staff, 

and observed activities such as filter 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 the 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 emplacement panel(s) (presently panel five in the 

underground) is that when a filter potentially becomes covered with salt dust due to underground 

operations the RADOS CAM has a mechanism to automatically 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 periodically the filter transport “truck” mechanism freezes or jams and 

causes the RADOS to malfunction requiring technician intervention. (Figure 1: RADOS Filter 

Transport Mechanism, Alpha Spectrum Screen, and RADOS Operation Screen) 

 
4

As noted in Section 4.0 above, see COB-A2009-S24, DOE/WIPP has attempted to mitigate this 

issue by slowing down the automatic change mechanism, requiring an alarm-that will be noted at 

the Central Monitoring Room (CMR) requiring more effective response, 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 RADOS CAMs are not allowed to change filters simultaneously. 

In addition, improved staff training, change filter cleaning, and filter replacement procedures 

have been implemented. These changes should mitigate this “freezing” issue and ensure 

continuous sample of air from the operating 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 notifies the CMR of an alarm and forces the mine 

air exhaust to go into HEPA filtration in the event 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 discussed 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 installing the ability to examine the RADOS 

operations and spectrum computer screens remotely via the WIPP network system. This will 

give emergency response staff the ability to get a “first look” at a potential 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 continues to be a challenging problem. As 

noted in last year’s Subpart A annual inspection report, the shrouded 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 have 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 with this approach. (Figure 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 working on testing a back flush system to clean probes in place 

in real-time. They have also ordered new probes that may not become salt loaded as easily. 

Once again, the WIPP staff has continued to be aggressive 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 located at the bottom of the WIPP air exhaust shaft 

and presently samples only the air flow pathway from the waste emplacement mine drifts. 
5

 Leading up to this inspection, the Agency had two major objections to using Station D to 

replace or augment Station A. First, all air exhaust flow pathways are required to be sampled to 

ensure representative samples are captured from the 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 waste handling shaft air flow, the waste emplacement 

panel air flow, and the experimental air flow pathways. Second, how would sample filters be 

collected at Station D if a potential release event did occur so that the source term could be 

determined? As experienced during the drum puncture 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 Station 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-A2006-3). Secondly, the 

potential use of RADOS CAMs at Station D must be evaluated, since this allows the notification 

of the CMR in the event of a captured release, switching automatically 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 second 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 calculations performed using 

the computer code HOTSPOT. These calculations are performed in the event of a potential 
6

radioactive release. They include source term estimation, present weather conditions, and an 

inceasingly accurate estimate of the potential release source term (from first estimate to actual 

laboratory measurement). HOTSPOT calculations estimate the potential dose to the public and 

are used to guide response decision making at the site. 

 EPA also toured the WIPP radiochemistry laboratory. Lab staff demonstrated 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 Steps) EPA found all activities 

consistent with established procedures. 

 

5.0 Summary of Findings

 EPA concludes that DOE adequately implements a radiological monitoring and sampling 

program for WIPP disposal operations and appropriately 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 RADOS 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, because of the importance of this sampling system, 

the Agency believes that DOE/WIPP should assure that 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 Energy (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 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 activity is to verify that DOE at WIPP can measure and calculate 

and has measured and calculated any actual or potential radiation dose to members of the public 

during management and storage of radioactive waste 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 verify 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 particular the EPA wishes to verify that DOE 

complies with the Subpart A standard is demonstrated by showing that the annual radiation dose 

to any member of the public in the general environment falls below the regulatory limits. 

Focal Areas for this Years Inspection: 

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

#During past years a number of potential changes 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 air flow, what have been the conditions of the 

sample filters? Have the filters had salt buildup 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 procedure has been developed by 

the site that is used to predict probe pull/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 laboratory 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 procedures used to calculate off-normal potential 

release during operations, use flow charts, photographs, etc as needed. Provide examples 
8

of various accidental scenarios with appropriate calculations-source term estimates, etc. 

Describe the process from start to finish, the steps taken to respond to off-normal 

situations? 

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

taken at Station A are representative samples? 

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 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 measurements are taken, and complete documentation 

that shows how compliance calculations are performed with an explanation of all input 

parameters and their derivation and all pertinent related to Subpart A requirements. Provide 

documentation and procedures related to subpart Subpart A compliance activities 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 (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: 

(1) Discharges of radioactive material and direct 

radiation from such management and storage and (2) 

all operations covered by Part 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 that 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 Implementation 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 Emergency 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 documents 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 the 

member 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 critical organ radiation 

dose for the maximally exposed individual 

(or a hypothetical individual 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 radiation 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 report demonstrates 

that DOE is using appropriate parameters 

in dose calculations. 

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 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-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 monitoring, 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 Implementation Plan for Subpart A 

(DOE/WIPP 00-3121:COB-A2009-A) 

Section 3.3.3 states that 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-A2009-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 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, 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 with 

Shrouded 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 underestimate 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 uses 

Section 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) discusses 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 verify 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 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-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