### 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) con ducted an annual inspection of the**  **Department of Energy (DOE) Waste Isolation Pilot Pl ant (WIPP) July 22 to July 24, 2008 as part**  **of our continued oversight program. This inspectio n 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 re leases to the public due to normal**  **waste disposal operations and any unplanned or acci dental releases that might occur during**  **disposal operations. Again this year EPA reexamine d 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 rou tine 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 ra diation sample locations and equipment,**  **sample processing, and reviewed the computational m ethods 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 mo nitoring program during the past**  **year, and responded aggressively and appropriately to Station A issues. Moisture and salt**  **loading continues to challenge the Station A sampli ng location. EPA verified that DOE**  **increased probe cleaning frequency as needed and co ntinued to work toward a solution to this**  **persistent problem. DOE continues to have an effec tive 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 ins pection.** 

2.0 Inspection Scope

**The scope of this inspection was to verify that WI PP continues to effectively capture,**  **measure, and calculate radiation doses to members o f the public during waste disposal**  **operations. Inspection activities included an exam ination 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 i mpact 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 de tectable 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, T homas Kesterson, Steve Holmes, and**  **Cody Johnson. Jerry Fox and Chris Timm of Pecos Ma nagement 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 c hanges to the program during the past year:** 

**- Upgraded Station A flow controllers and enhanced preventative maintenance.** 

**- Enhanced preventive maintenance of the air transp ort lines (because of indications of**  **corrosion) and filter holders, because of corrosion and thread wear.** 

**- Installing RADOS CAMs (continuous air monitors) i n Panel 5.** 

**- Procedures for both effluent monitoring and labor atory analysis have had minor changes.** 

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

**- Continued to evaluate and enhance processes to st udy Station A shrouded probes to determine**  **the amount of loading and techniques to predict whe n a probe may have salt build-up that require**  **cleaning.**

**The EPA inspector observed various activities to ve rify effective implementation of** 

### 3

**procedures. EPA reviewed procedures and implementa tion 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 pro bes in the air exhaust of Panel**  **4; these new systems appear to have solved the fals e alarms recorded during 2005 and 2006.**  **After the shake down period the RADOS CAMS have ope rated effectively. Site staff updated**  **the RADOS CAMs MCA boards, CPU, and operating syste m. 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 contin ues 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 8 th**  

### 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 8 th**  

### 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 10 th**  

### and July 8 **th** 

### when the probes were**changed. At this point the site went to bi weekly probe exchanges from monthly,**  **however at the July 22 nd**  

### 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 in**  **creased (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 (COB**  **A2008-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 * Sourc **e 2007 3**  **rd** 

### Quarter Station B Pu238 4.41E-02 8.11E-03 Reser **ve 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 O**  **riginal** *** in picoCurie per sample**

**In brief, composites of Station A are processed mon thly and Stations B and C are done**  **quarterly using these general steps (COB-A2008-L1-P rocess Steps):** 

**-Tracers are added and Laboratory Control Standards are created.**  **-Filters are combined, the filters are mixed acid d igested and completely dissolved.**  **-The filter solution is separated into equal fracti ons (parts), one saved as backup (the reserve**  **fraction). -The first fraction is chemically separated to retr**  **ieve 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 a**  **nd other gamma emitters to determine**

**concentrations. -Quality control activities were done.**  **-An activity review is done to determine if any mea surements are above TPU (total propagated**  **uncertainty) and MDC (minimum detectable concentrat ion).**  **-If an isotope is detected additional laboratory ru ns of the backups are performed to verify** 

**detection.**

**These steps were done as routine processing for th ese samples listed in Table 1, and the**  **isotopes noted in the table were detected. The val ues measured are small fractions of EPA’s**  **annual dose limits stated in 40 CFR 191 Subpart A o r EPA’s NESHAPs regulations. There has**  **been speculation about sources of these low concent rations; however DOE has not found any**  **instance of a potential release during waste emplac ement 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 an d 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 i n Panel 4 and the location being** 

**installed in Panel 5. EPA found all activities con sistent with established procedures.** 

4.6 Future Activities

**DOE plans to “Implement a predictive maintenance pr ocedure that will be conducted**  **weekly to determine probes inspection frequency bas ed 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 futur e. 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 rad iological monitoring and sampling**  **program for WIPP disposal operations and appropriat ely performs calculations to estimate**  **potential releases to the public. EPA had one find ing 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 (DO E) 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, Subpar t 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 limit s expressed in Section 191.03 Standards.** 

Scope **: The scope of this inspection activity is to veri fy that DOE at WIPP has measured and**  **calculated any actual or potential radiation dose t o members of the public during management**  **and storage of radioactive waste during the past ye ar of site operation. Inspection activities will**  **include an examination of the description of monito ring and sampling equipment both on and off**  **site, and in the underground.**

**The specific purpose of this inspection is to verif y 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 AN D STORAGE OF**  **TRANSURANIC WASTE (40 CFR Part 191, Subpart A) at t he WASTE ISOLATION PILOT** 

**PLANT (402-R-97-001), Section 4.2, Page 15. In particul**  **ar the EPA wishes to verify that DOE complies with the Subpart A standard is demonstrate**  **d by showing that the annual radiation dose to any member of the public in the general environm**  **ent 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 contr**  **oller 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 chan**  **ged in recent years?**

**- How are composite samples handled and processed, me**  **asurement accuracy, and implications of laboratory standards used?** 

**- Evaluation and explanation of measured values in co**  **mposite samples, minimum detectable limits, etc.?** 

**- Provide a presentation of the process and procedure**  **s used to calculate off-normal potential release during operations, use flow chart**  **s, photographs, etc as needed. Provide examples of various accidental scenarios with appro**  **priate calculations. Please wants to see, from start to finish, the steps taken to respo**  **nd to off-normal situations?**

### 8

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

Duration **: The EPA expects to complete its inspection in thr ee 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 ann ual Safety Analysis**  **Report, information that describes how measurements are taken, and complete documentation**  **that shows how compliance calculations are performe d with an explanation of all input**  **parameters and their derivation and all pertinent r elated to Subpart A requirements. Provide**  **documentation and procedures related to subpart Sub part 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-R**

**97-001 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-R** 

**97-001 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 (COB**  **A2008-Ja,-Jb) demonstrates that normal operations are examined. CH Waste Documented** **Safety Analysis (DOE/WIPP 95-2065:COB A2008-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-R** 

**97-001 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 o n**  **which contaminated particles have been deposited, swimming in ponds in which radionuclides have**  **been deposited are considered? EPA 402-R** 

**97-001 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 (COB** 

**A2008-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 (COB** 

**A2008-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 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-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:COB A2008-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-R** 

**97-001 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 COB**  **A2008-S16). Subsequent probe pull photos show that weekly cleaning has mitigated salt**  **buildup and restored representative sampling**

**at Station A. EPA 402-R** 

**97-001 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-R** 

**97-001 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-R** 

**97-001 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 191A**  **AO-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:COB**  **A2006-4) 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-R 97-001 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:COB**  **A2008-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:COB** **A2008-G) and RH (DOE/WIPP 06-3174: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:COB A2008-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 off**  **site 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