DOCKET NO: A-98-49 

Item: II-B3-108

2008 - Subpart A Inspection Report 

INSPECTION No. EPA-WIPP-7.08-22a 

OF THE 

WASTE ISOLATION PILOT PLANT 

July 22 to July 24, 2008 

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 2008
 Table of Contents 

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

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

3.0 Inspection Team, Observers, and Participants .......................................................................... 1 

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

 

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

Tables

Table 1 Laboratory Samples With Detected Isotopes

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 (DOE) Waste Isolation Pilot Plant (WIPP) July 22 to July 24, 2008 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 radiation releases to the public due to normal 

waste disposal operations and any unplanned or accidental releases that might occur during 

disposal operations. Again this year EPA reexamined DOE’s continued moisture problems and 

salt loading at the Station A sampling location in the air exhaust shaft. EPA also focused on 

instances of potential releases detected during routine composite sample measurements. EPA 

inspectors examined WIPP’s emission control devices and methods used to estimate radiation 

doses to the public. In addition, EPA inspected radiation sample locations and equipment, 

sample processing, and reviewed the computational methods used to estimate dose. This year 

EPA was able to observe filter changes, probe pulls, and probe replacement at Station A. 

 EPA found that DOE 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. EPA verified that DOE 

increased probe cleaning frequency as needed and continued to work toward a solution to this 

persistent problem. DOE continues to have an effective radiation sampling program because of 

the diligence of site staff, and can calculate both yearly and accidental dose estimates adequately. 

EPA had one finding that was cleared during the 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 routine periodic composite samples in which 

radioactivity was detected at just above minimum detectable concentrations. 

3.0 Inspection Team, Observers, and Participants

 The inspection team consisted of three EPA staff. Three members of the New Mexico 

Environmental Department observed the inspection, Thomas Kesterson, Steve Holmes, and 

Cody Johnson. Jerry Fox and Chris Timm of Pecos Management Services also observed the 

inspection activities. 
2

Inspection Team Member Position Affiliation

Chuck Byrum Inspection Leader EPA 

Nick Stone Inspector EPA 

Tom Peake 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 Curtis Chester 

Mansour Akbarzadeh Dave Speed 

Linda Frank-Supka Tom Goff 

Dave Kump Ed Flynn 

4.0 Performance of the Inspection 

The inspection began on Tuesday, July 22, 2008 with an opening meeting that included 

presentations on changes in air monitoring and WIPP laboratory activities (COB-M2008-I3a, -

I3b and -I5). Site staff discussed changes in the program since the last EPA inspection in July 

2007. These presentations included the following changes to the program during the past year: 

- Upgraded Station A flow controllers and enhanced preventative maintenance. 

- Enhanced preventive maintenance of the air transport lines (because of indications of 

corrosion) and filter holders, because of corrosion and thread wear. 

- Installing RADOS CAMs (continuous air monitors) in Panel 5. 

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

- Changes related to the underground CAMs; upgraded RADOS CAMs in Panel 4. 

- Continued to evaluate and enhance processes to study Station A shrouded probes to determine 

the amount of loading and techniques to predict when a probe may have salt build-up that require 

cleaning. 

The EPA inspector observed various activities to verify effective implementation of 
3

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 sampling filter changes and probe pulls at Stations A (Figure 4), 

examined photographs of the monthly shrouded probe changes (COB-A2008-S4 to -S7, Figure 

1), and reviewed underground RADOS CAM locations. 

 4.2 RADOS CAMs Appear to have Solved False Alarms 

DOE has installed two RADOS CAMs using shrouded probes in the air exhaust of Panel 

4; these new systems appear to have solved the false alarms recorded during 2005 and 2006. 

After the shake down period the RADOS CAMS have operated effectively. Site staff updated 

the RADOS CAMs MCA boards, CPU, and operating system. RADOS CAMs are being 

installed in the air exhaust of Panel 5. 

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. 

Normally during the fall and winter seasons DOE has persistent moisture related salt buildup at 

Station A. However, this year DOE was surprised by unusual salt buildup on both the primary 

and secondary probes during the July 8th probe pull (Figure 1-State and DOE photos July 8). 

Normally this period of 

time is not troubled with 

salt probe buildup and 

probes are usually 

changed on a monthly 

schedule. This occurrence 

may be due to mining near 

the air exhaust shaft. 

Finding: After seeing the 

State and DOE 

photographs of the probes 

removed on July 8th EPA 

believed that it would be 

difficult to prove that 

DOE was able to verify 

that Station A was able to 

record representative 

samples (See Checklist 

item 23b). Therefore, 

EPA informed the site staff at the opening meeting that the Agency had a finding. Station A may 
4

not have been collecting representative 

samples for some period of time between 

June 10th and July 8th when the probes were 

changed. At this point the site went to biweekly probe exchanges from monthly, 

however at the July 22nd probe exchange one 

of the compliance probes, the primary 

Station A-3 probe, also failed because of salt 

buildup in the waistline of the shrouded 

probe (Figure 2-Primary Probe July 22). Site 

personnel were able to clear this finding 

during the inspection by increasing the probe 

exchange frequency to weekly and 

demonstrating that there were no radioactive 

releases during this time period and that 

other sampling locations, underground 

CAMs, and RADOS CAMs operated 

effectively during this period and did not 

record any release events (COB-A2008-

S16). Subsequent probe exchanges verify that an increased (to weekly) probe exchange 

frequency has mitigated the salt problem at 

Station A (Figure 3-Secondary Probe July 

29). 

4.4 Low Concentrations Found in Routine 

Laboratory Composite Measurements 

 During the past year the WIPP 

laboratory measured very low levels of 

radioactive concentrations, just above 

minimum detectable concentrations in 

several periodic composite samples during 

routine measurements. The WIPP laboratory 

confirmed the values. The EPA inspector 

asked for and received an explanation of the 

processes used by the laboratory (COBA2008-L1) and the results of the laboratory 

measurements done to obtain these results 

(COB-A2008-L2 and -L3 are examples of 

the results). 
5

Table 1 - Laboratory Samples With Detected Isotopes

Date Composite Location Isotopes Measurement* MDC* Source

2007 3rd Quarter Station B Pu238 4.41E-02 8.11E-03 Reserve Fraction 

2007 September Station A Pu239/240 4.63E-02 1.19E-02 Reserve Fraction 

2008 February Station A Pu239/241 3.36E-01 8.67E-03 Original 

2008 February Station A Am241 1.39E-01 1.53E-02 Original 

* in picoCurie per sample 

In brief, composites of Station A are processed monthly and Stations B and C are done 

quarterly using these general steps (COB-A2008-L1-Process Steps): 

-Tracers are added and Laboratory Control Standards are created. 

-Filters are combined, the filters are mixed acid digested and completely dissolved. 

-The filter solution is separated into equal fractions (parts), one saved as backup (the reserve 

fraction). 

-The first fraction is chemically separated to retrieve individual isotopes and mounted for 

measurement. 

-Each isotope is counted; in the Alpha Spectrometer-for U, Pu, Am; the Gas Proportional 

Counter for Sr; and the Gamma Spectrometer for Cs and other gamma emitters to determine 

concentrations. 

-Quality control activities were done. 

-An activity review is done to determine if any measurements are above TPU (total propagated 

uncertainty) and MDC (minimum detectable concentration). 

-If an isotope is detected additional laboratory runs of the backups are performed to verify 

detection. 

 These steps were done as routine processing for these samples listed in Table 1, and the 

isotopes noted in the table were detected. The values measured are small fractions of EPA’s 

annual dose limits stated in 40 CFR 191 Subpart A or EPA’s NESHAPs regulations. There has 

been speculation about sources of these low concentrations; however DOE has not found any 

instance of a potential release during waste emplacement operations for the time periods of the 

composite collection and the measured values are so far below regulatory limits as to be 

insignificant, on the order of .0001 mrem/year dose (COB-A2008-S10). EPA believes these 

measurements are emblematic of the sensitivity and resolution of WIPP’s laboratory techniques 

and EPA appreciates DOE’s diligence in reporting and confirming the measurements. 
6

4.5 Other Inspection Activities 

 EPA observed filter changes and probe exchanges at Stations A (Figure 4 Station A 

Probe Pull July 22, 2008) and verified appropriate implementation of site procedures. The EPA 

inspector also examined the underground RADOS CAM in Panel 4 and the location being 

installed in Panel 5. EPA found all activities consistent with established procedures. 

4.6 Future Activities 

DOE plans to “Implement a predictive maintenance procedure that will be conducted 

weekly to determine probes inspection frequency based on atmospheric conditions, mining 

conditions, and status of Station D availability...” (COB-A2008-S16) to attempt to prevent 

recurrence of Station A probe failures in the future. DOE also plans to update Stations B, C, and 

D flow controllers and hardware. 

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. EPA had one finding that was cleared during the course of the 

inspection at WIPP. EPA does not have concerns. 
7

Attachment A: Inspection Plan and Checklist 

WIPP Inspection Plan - 40 CFR 191, Subpart A for the year 2008

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 Section 191.03 Standards. 

Scope: The scope of this inspection activity is to verify that DOE at WIPP 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 the past two years 

a number of potential changes were discussed, such as new methods to evaluate salt 

build-up on Station A probes and new air flow controller at Station A. What is the status 

of these activities? 

- Verify that the underground CAM alarms continue to be solved and have not continued. 

- What has been the performance and dependability of the air sampler at the air exhaust of 

Panel 4. Update and status of the RADOS CAM? Are samplers installed at Panel 5 and 

their status? 

- Has the increased cleaning and changing of Station A Probes and transport lines had an 

impact on salt loading at Station A. What has changed in recent years? 

- How are composite samples handled and processed, measurement accuracy, and 

implications of laboratory standards used? 

- Evaluation and explanation of measured values in composite samples, minimum 

detectable limits, etc.? 

- 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 of various accidental scenarios with appropriate calculations. Please wants to 

see, from start to finish, the steps taken to respond to off-normal situations? 
8

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 21, 2008. 

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 2008 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 

(DOE/WIPP 07-2225:COB-A2008-C) 

Executive Summary documents the results 

of DOE’s efforts to consider all activities 

that impact compliance. 

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? 

EPA 402-R97-001 

Section 2.3, 

Page 5 

Section 3.0 of the Implementation Plan for 

Subpart A (DOE/WIPP 00-3121: COB-A2008-

A), documents the plan to show how this 

requirement is examined. QAPP for Sampling 

Emissions (WP 12-RC.01:COB-A2008-F), 

documents the QA requirements for the sampling 

of emissions. Annual NESHAP report (COBA2008-Ja,-Jb) demonstrates that normal 

operations are examined. CH Waste Documented 

Safety Analysis (DOE/WIPP 95-2065:COBA2008-G) and RH Waste DSA (DOE/WIPP 06-

3174:COB-A2008-H) documents DOE’s review 

of potential accidents at WIPP. Procedure 

Emergency Radiological Control Response (WP 

12-HP4000:COB-A2008-K) 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-R97-001 

Section 2.4, 

Page 5 

DOE/WIPP 07-2225 Section 2.2.15 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 

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-A2008-Ja,-

Jb) demonstrates that these exposure 

mechanisms are included. 

Sat. 
10

# CHECKLIST QUESTION July 2008 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-A2008-A) explains 

DOE’s plan to fulfill this 

requirement. Annual Site 

Environmental Report (DOE/WIPP 

07-2225:COB-A2008-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 

DOE/WIPP 07-2225 Section 1.3.2 

and the Annual NESHAP report 

(COB-A2008-Ja,-Jb) 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 

DOE/WIPP 07-2225 Section 1.3.2 

and the Annual NESHAP report 

(COB-A2008-Ja,-Jb) 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. 

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 

DOE/WIPP 07-2225:COB-A2008-

C Section 1.3.2 and the Annual 

NESHAP report (COB-A2008-Ja,-

Jb) 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 2008 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-A2008-A) describes the 

“reference man” parameters as 

described in the CAP88-PC computer 

code. Annual NESHAP report 

(COB-A2008-Ja,-Jb,-S15) 

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 (COBA2008-Ja,-Jb) 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-A2008-Ja,-Jb) 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 

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 

Section 3.2 of DOE/WIPP 00-3121 states 

that DOE uses the atmospheric dispersion 

code (GXQ) to determine concentrations 

for accidental releases. GXQ 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 2008 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 

Annual NESHAP report (COBA2008-Ja,-Jb) 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-A2008-A) states 

that DOE is using these values as 

exposure parameters. The Annual 

NESHAP report (COB-A2008-Ja,-

Jb) demonstrates that DOE is using 

these parameters in dose 

calculations. COB-A2008-S15 

shows a copy of a NESHAPs CAP 

88-PC run with these parameter 

marked. 

Sat. 
13

# CHECKLIST QUESTION July 2008 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-A2008-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:COBA2008-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 4.1 the 

location of sampling sites. 

Sat. 
14

# CHECKLIST QUESTION July 2008 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-A2008-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-A2008-Ja,-Jb) 

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. 

Finding: possible non-representative sampled 

at Station A. CLEARED-During the 

inspection. DOE committed to weekly probe 

cleanings until it is clear the unique conditions 

have changed (Corrective action report COBA2008-S16). Subsequent probe pull photos 

show that weekly cleaning has mitigated salt 

buildup and restored representative sampling 

at Station A. 

EPA 402-R97-001 Section 

3.1, Page 11, 

(2(ii)) 

Environmental Monitoring Plan 

(DOE/WIPP 99-2194:COB-A2008-1) 

Section 5.2.4 and DOE/WIPP 00-

3121:COB-A2008-A Section 3.3.2 states 

that sample sites will acquire representative 

samples. Recent probe pull photographs at 

Station A (State Photos:COB-A2008-S4,-S6 

and DOE Photos:COB-A2008-S5,-S7 for 

example) show that the probes have had salt 

loading and that the probe, in these cases, do 

not pass minimum acceptance criteria. 

Even though salt loading continues to be a 

problem at Station A DOE continues to 

aggressively increase the probe cleaning 

schedule whenever salt loading increases. 

However, the recent failures on July 8, 2008 

demonstrates that both the primary (A-3) 

probe and the backup/secondary (A-2) 

probe can fail at the same time and that 

Station A may not be acquiring 

representative samples.

Sat. 

Cleared 

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-A2008-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 2008 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-A2008-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-A2008-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:COBA2008-B) discusses release points 

measured confirm compliance with 

this requirement. 

Sat. 
16

# CHECKLIST QUESTION July 2008 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:COBA2008-G) and RH (DOE/WIPP06-3174:COB-A2008-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-A2008-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-A2008-

1) states: “Station A exhausts 

unfiltered air from the underground 

repository to the atmosphere. 

Station B exhausts HEPA filtered 

air from the underground 

repository to the atmosphere when 

in Filtration Mode of operation. 

Station C exhausts HEPA filtered 

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 2008 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 2008 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:COBA2008-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 

06-2225:COB-A2008-C) Chapter 4 

demonstrates that DOE’s 

environmental program monitors 

other release points and critical 

receptor locations. 

Sat. 
19

# CHECKLIST QUESTION July 2008 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-A2008-A) documents that 

DOE’s plans to report results yearly. 

The Annual NESHAP (COB-A2008-

Ja,-Jb) report demonstrates that DOE 

reports results yearly. 

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 

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 

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-A2008-A documents 

that DOE’s plans to report results 

yearly. 

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