DOCKET NO: A-98-49

Item: II-B3-127

2013 - Subpart A Inspection Report

INSPECTION No. EPA-WIPP-10.13-22a

OF THE

WASTE ISOLATION PILOT PLANT

October 22 – 24, 2013

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

January 2014
1

Table of Contents

1.0 Executive Summary...................................................................................................................2

2.0 Inspection Scope ........................................................................................................................3

3.0 Inspection Team, Observers, and Participants...........................................................................3

4.0 Performance of the Inspection ...................................................................................................4

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

Attachments

Attachment A Inspection Plan and Checklist

Attachment B Documents Reviewed 
2

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) from October 22 to 24, 2013 as 

part of its 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 remains in 

compliance with the 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. EPA inspectors examined WIPP’s emission monitoring 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. 

EPA verified that site staff is able to calculate both yearly and accidental dose estimates 

adequately. 

EPA found that there have been no major off-normal incidents related to radiation control or air 

sampling, and that DOE has continued to effectively manage its air sampling program to provide 

representative samples. DOE’s decision to rely exclusively on Skids A-2 and A-3 at Station A 

will increase the predictability of managing salt occlusion on the probes. DOE continues to have 

an effective radiation sampling program because of this continued diligence. Inspectors made 

two observations related to procedure updates, both of which were corrected before this report 

was completed. EPA did not identify any findings or concerns during 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. EPA also 

addressed the site’s ability to characterize a radiological release during an emergency, the 

handling of samples, and the generation analytical results by the WIPP laboratory. This 

inspection was conducted under the authority of 40 CFR 191, Subpart A.

3.0 Inspection Team, Observers, and Participants

The inspection team consisted of three EPA staff. Trais Kliphuis of the State of New Mexico 

Environmental Department observed the inspection. 

Inspection Team Member Position Affiliation

Nick Stone Inspection Lead EPA Region 6

Kathleen Economy Inspector EPA ORIA

Jonathan Walsh Inspector EPA ORIA
3

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

Participant 

DOE/Contractor Participates

Participant 

Larry Madl Art Chavez

Jacqueline Davis Jennifer Hendrickson 

Mansour Akbarzadeh Ginny Jones

GinnyDavid Squires

Adan Pena Rob Hayes

David Squires Randy Britain

4.0 Performance of the Inspection

The inspection began on Tuesday, October 22, 2013, with an opening meeting that included 

presentations on changes in air monitoring and WIPP laboratory activities. Site staff discussed 

changes in the program since the last EPA inspection in July 2012. These presentations included 

the following updates and changes to the program:

- After several years of problems with salt occlusion of the shrouded probe at Station A, Skid A1, the program will no longer use A-1. This will allow a longer probe pull interval of four weeks 

in the absence of heavy mining, and make it unnecessary to consider meteorological impacts on 

salt occlusion of the probe.

- Flow control and backup power upgrades are underway at Station B because the current 

instrumentation is no longer supported by the manufacturer. 

- Underground RADOS CAMs are operating in the exhaust drifts of Panels 6 and 7. CAMS are 

expected to be moved from Panel 6 to Panel 8, following the conclusion of waste disposal in 

Panel 6, in early 2014.

- Consequence Assessment Dose Projection procedures have been updated to allow the 

simultaneous modeling of combinations of container type and breach scenario. Additionally, 

procedures now allow consequence assessment engineers to perform an initial emergency plume 

remotely, using either NARAC or a hand calculation.

- WIPP laboratories reported that small but detectable amounts of 239/240 Pu were observed in 

FAS, Station A, and environmental sampling filters, including blanks, between September and 

November 2013. Filters were stored in close proximity to Pu check sources. After changing this, 

and conducting decontamination activities, no activity above background has been detected in 

2013 samples. 
4

The EPA inspection team reviewed procedures, interviewed site staff, and observed activities to 

verify the effective implementation of procedures relevant to Subpart A. These activities are 

described in detail below.

4.1 Stations A, B, and C

Station A, which samples unfiltered air exhausted from the WIPP underground, has been a focus 

of EPA in several past inspections, due to the tendency of salt to occlude the sampling probes, 

with the potential to render aerosol samples unrepresentative. Skid A-1, which is nearest to the 

source of water in the exhaust shaft, has been uniquely problematic, and has created an impetus 

for DOE to change the probes on a frequent basis, up to biweekly. The decision to not operate 

Skid A-1 confers several advantages to the program. The most reliable sampling points, Skids A2 and A-3, are employed interchangeably as the sampler of record and back-up. Probe pulls are 

reduced to a monthly frequency, reduced only in response to heavy mining in the vicinity of the 

exhaust. The need to account for meteorology in scheduling probe pulls is obviated. Skid A-1 is 

essentially on standby as a back-up sampler if it is ever needed.

Site staff has informed EPA of deviations from the typical probe change schedule during the past 

year. In summer 2013, the probes remained in place for six weeks, due to the unavailability of a 

crane to perform the change. When they were removed on June 5, probes on A-2 and A-3 passed, 

confirming that samples taken during that time were valid. A1 failed at the shroud. See Figure 1 

for photographs of the probes. In addition, during a probe change on Skid A-2, an exterior weld 

on the transfer line supporting the probe was observed to have cracked. The transport line has 

been replaced. Because the crack did not extend to the interior of the transport line, there was no 

impact to sampling.
5

Figure 1: Adapted from June 5, 2013 Probe Pull Report

SKID A-1

Probe acceptance 

determinations:

Nozzle – passed, Shroud –

failed

SKID A-2

Probe acceptance 

determinations:

Nozzle – passed, Shroud –

passed

SKID A-3

Probe acceptance 

determinations:

Nozzle – passed, Shroud –

passed

Front view as found – focus on 

nozzle tip

Front view as found – focus on 

nozzle tip

Front view as found – focus 

on nozzle tip

Shroud outside view as found Shroud outside view as found Shroud outside view as found

The inspection team performed a walk-down of Station A on October 23. All flow meters were 

within calibration. Skid A-1 was switched off, and Skids A-2 and Skid A-3 were both operating 

within the intended ranges for volumetric flow and pressure differential across the filter.

The inspection team also visited Station B and Station C to verify calibration dates and flow 

rates. At Station B, Skid B-2 was tagged out and disassembled, and new instrumentation had 

been installed. Skid B-1 was calibrated and operating correctly. 

Site personnel alerted inspectors to the fact that the flow meter at Station C, which samples the 

exhaust from the waste handling building, had not been recalibrated. During the previous 

inspection, EPA observed that the flow meter’s calibration had expired on May 5, 2012. A new 
6

procedure for calibrating the flow meter, which was a 2011 upgrade, still has not been finalized.

There is no reason to believe that Station C would fail to detect a release, and numerous fixed air 

samplers throughout the waste handling areas provide confirmation that no releases have taken 

place. EPA recommended resolving the calibration issue as quickly as possible, so that data from 

Station C could be used without question in the case of an off-normal event. Documentation that 

Station C’s calibration has been verified was provided to EPA on November 27 and Dec 2 (JPW20131022-05 and Work Orders 1202385C, 1203590C).

4.2 Consequence Analysis

On the afternoon of October 23, EPA inspectors met with Consequence Assessment staff in the 

Engineering building. The previous two inspections focused on consequence assessment drills 

and staff turnover. This year, the inspector discussed changes to WP 12-ER4916, Consequence 

Assessment Dose Projection. The procedure has been revised to be more useable, and to allow 

initial does estimates to be conducted remotely from the WIPP site in an emergency. The 

inspector asked whether the procedure had been updated to reflect incidents involving shielded 

containers, which were approved and emplaced in the repository more recently than the last EPA 

inspection. A review of WP 12-ER4916, Rev. 19, showed that shielded containers were not 

reflected in tables showing Material at Risk and Damage Ratios for each container type. Staff 

immediately submitted an update, and WP 12-ER4916, Rev. 20 became effective on 11/20/13.

4.3 Underground Sampling

During the underground tour on October 23, inspectors observed the continuous air monitors 

(CAMs) placed at the exhaust of Panel 7, where RH waste emplacement had begun in Room 7. 

CAM 151 was observed to be within calibration and operating with air flow and pressure 

differentials within the acceptable range. The inspection team also visited Station D, at the 

bottom of the exhaust shaft. A calibration sticker on Station D’s flow meter indicated that 

calibration had expired in September, however, the site was able to produce documentation 

showing that the flow control equipment had been recalibrated (JPW-20131022-02, -03).

4.4 WIPP Laboratory

EPA also inspected the WIPP laboratory, which supports annual NESHAP reporting and 

emergency response activities at WIPP. Inspectors again toured the laboratory itself and were 

given a presentation of the laboratory’s analytical services. Discussions with laboratory staff 

focused on the lab’s QA program. 

5.0 Summary of Findings

During the inspection EPA examined DOE’s activities over the past year. The inspection verified 

that DOE is correctly implementing procedures which allow it to accurately monitor and 

calculate possible radiation doses to members of the public due to WIPP site operation. The 

inspection checklist included as Attachment A specifically documents DOE’s compliance with 
7

each reporting expectation set forth in EPA’s WIPP Subpart A Guidance (402-R-97-001). Based 

on the inspection activities documented in this report, EPA concludes that DOE continues to 

adequately implement a radiological monitoring and sampling program for WIPP disposal 

operations in which it collects representative samples and appropriately performs calculations to 

estimate potential releases to the public. The results of this program, documented in the Annual 

Periodic Confirmatory Measurement Compliance Report for Calendar Year 2012 (RES 12-522) 

show that the calculated annual effective dose equivalent (EDE) value to the maximally exposed 

individual resulting from normal operations conducted at WIPP is less than 1.00x10-05 millirem, 

demonstrating that DOE remains compliant with the dose limits expressed in 40 CFR 191.03(b)

and in 40 CFR 61, Subpart H. EPA does not have any findings or concerns.
8

Attachment A

Inspection Plan and Checklist

Purpose: 

EPA will verify that the Department of Energy (DOE) has accurately monitored and calculated 

possible radiation doses to members of the public, due either to normal operations or to any 

accidental releases that 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 includes all activities performed by DOE at WIPP to measure and 

calculate any actual or potential radiation dose to members of the public during management and 

storage of radioactive waste, specifically during the past year of site operation. Inspection 

activities will include an examination of monitoring procedures and sampling equipment both on 

and off site, and in the underground. 

The purpose of this inspection is to verify and confirm that DOE at WIPP has complied with the 

“Compliance reporting” expectations of EPA’s as specified in Guidance For the Implementation 

of EPA’s Standards 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. 

Focal Areas for the 2013 Inspection:

- What changes have taken place in air sampling since last year’s inspection?

- What potential changes to air sampling would result from the development of a new 

experimental area? 

- During past years a number of potential changes were discussed to evaluate and address 

salt occlusion 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.

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

implications of laboratory standards used? 

- Provide a presentation of the process and procedures used to calculate off-normal 

potential release during operations. Describe the process used to respond to off-normal 

situations from start to finish.

- 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.
9

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.

Inspection Dates: October 22-24, 2013.

Information Requested: DOE will provide documentation and procedures related to Subpart A 

compliance activities as in past years. Before the inspection, DOE will provide 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. 

Provide to EPA the 2012 Annual Safety Analysis Report.

Inspection Checklist

# CHECKLIST QUESTION November 

2013

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 discharges of 

radioactive material and direct radiation from 

such management and storage shall not exceed 

25 millirems to the whole body and 75 

millirems to any other critical organ.” 40 CFR 

191.03(b) 

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?

Activities include those at “all WIPP facilities, 

both at above-ground locations and in the 

underground disposal system” and those related 

to “arrival or receipt of waste, inspections of 

containers, unloading, and waste movement.”

EPA 402-R97-001

Section 2.3, 

Page 4

The Annual Site Environmental 

Report for 2011 (DOE/WIPP 12-3489) 

Executive Summary documents 

DOE’s efforts to consider all activities 

that impact compliance. The Annual 

Periodic Confirmatory Measurement 

Compliance Report for Calendar Year 

2012 (RES 12-522, hereafter referred 

to as the annual NESHAP report) and 

inspection activities confirm that all 

waste handling activities are 

considered in determining compliance.

Sat
10

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, Rev. 3) documents how this 

requirement is met, both for normal 

operation and accidental releases. 

Annual NESHAP report demonstrates 

that normal operations are fully 

examined. 

CH Waste Documented Safety 

Analysis (DOE/WIPP 95-2065, Rev. 

10) and RH Waste DSA (DOE/WIPP 

06-3174, Rev. 0) documents DOE’s 

review of potential accidents at WIPP.

Procedure Emergency Radiological 

Control Response (WP 12-HP4000, 

Rev. 6) and Consequence Assessment 

Dose Projection (WP 12-ER4916, Rev 

20) document radiological emergency 

response activities, including an initial 

assessment of possible dose to the 

public. 

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

Section 2.1 of the Implementation 

Plan for Subpart A describes the 

process by which the air pathway was 

established as the credible release 

pathway, and the use of environmental 

monitoring of other exposure 

pathways to confirm that this remains 

the case.(DOE/WIPP-00-3121, Rev. 4, 

p.8)

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 the 

Implementation Plan for Subpart A 

documents methods for measuring 

these potential exposure pathways 

(DOE/WIPP 00-3121, Rev. 4).

Section 4.8.4 of the ASER documents 

the consideration of dose from these 

pathways (DOE/WIPP-11-2225). 

Annual NESHAP report confirms that 

these exposure mechanisms are 

included in dose calculations.

Sat
11

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-R97-001

Section 2.4, 

Page 5 and 

page 6.

Yes. Section 2.1 of the 

Implementation Plan for Subpart A 

explains DOE’s plan to fulfill this 

requirement(DOE/WIPP-00-3121, 

Rev. 4). Annual Site Environmental 

Report Chapter 4 demonstrates that 

DOE implements groundwater 

surveillance, biota sampling and offsite air monitoring programs 

(DOE/WIPP-11-2225).

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-R97-001

Section 2.5, 

Page 6.

EPA 402-R97-001

Section 2.5, 

Page 7

Section 3.1 of DOE/WIPP-00-3121 

Rev. 4 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.)

“The location of the maximally exposed 

individual is the location where an actual 

individual lives or works who receives the 

maximum annual radiation dose from the 

source.”

EPA 402-R97-001

Section 2.6.1, 

Page 8

For Subpart A, DOE assumes that the 

member of the public resides, “... 

year-round at the fence line in the 

northwest sector” (DOE/WIPP-11-

2225, Section 4.8.4.3). Section 1.3.2 

of the ASER demonstrates that DOE 

considers doses at appropriate offsite 

points, such as Smith Ranch located 

7.5 km away in the WNW sector 

(DOE/WIPP 11-2225).

The Annual Periodic Confirmatory 

Measurement Compliance Report for 

the DOE WIPP for Calendar Year 

2012, or “2012 NESHAP Report,” 

identifies Smith Ranch as the location 

of the maximally exposed individual.

The nearest farms, dairies, and beef 

ranching activities are also considered. 

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-R97-001

Section 2.6.1, 

Page 8

Yes. See checklist Item 7. Sat
12

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-R97-001

Section 2.6.1, 

Page 8

Yes. See checklist Item 7. Sat

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-R97-001

Section 2.6.2, 

Page 8

Section 3.2 of the Implementation 

Plan for Subpart A describes the 

“reference man” parameters as 

described in the CAP88-PC computer 

code (DOE/WIPP 00-3121, Rev. 4).

These parameters are confirmed on 

page 8) of the CAP-88 output file 

included in the 2012 NESHAP report.

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-R97-001

Section 2.7.1, 

Page 8

Yes. The effective dose equivalent and 

table of organ dose equivalents is 

included in the 2012 annual NESHAP 

report CAP-88 output file.

Sat

12 Does DOE calculate radiation doses including 

all release points and reflecting evaluation of all 

exposure pathways?

EPA 402-R97-001

Section 2.7.1, 

Page 8

Section 2.1 of DOE/WIPP-00-3121, 

Rev. 4 states that the air pathway is the 

most credible, but that other exposure 

pathways are monitored to confirm the 

air pathway. Annual NESHAP report 

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-R97-001

Section 2.7.2, 

Page 9

Section 3.2 of DOE/WIPP-00-3121, 

Rev. 4 states that computer models 

will be used to calculate radiation 

doses during both routine operation 

and accidental releases. 

Sat

14 Does DOE use CAP88-PC to perform dose 

calculations?

EPA 402-R97-001

Section 2.7.2, 

Page 9

CAP88-PC is used for dose 

calculations for routine operations 

(DOE/WIPP-00-3121 Rev 4, Section 

3.2). Annual NESHAP report 

demonstrates that DOE is using 

CAP88-PC.

Sat
13

15 Does DOE use an alternate model for 

calculating radiation doses? If so, does DOE 

justify such usage? 

EPA 402-R97-001

Section 2.7.2, 

Page 10

DOE uses an atmospheric dispersion 

code (HOTSPOT) to estimate 

potential radiation due to accidental 

releases (DOE/WIPP-00-3121 Rev 4, 

Section 3.2). WP 12-ER4916 Rev. 20

states that HOTSPOT is used for 

accidental release calculations. DOE 

has demonstrated that HOTSPOT is a 

reasonable choice for emergency dose 

calculations.

Sat

16 Does DOE adequately support exposure 

parameters used in dose calculations?

EPA 402-R97-001

Section 2.7.3, 

Page 10

Annual NESHAP report includes 

CAP-88 output file, demonstrating that 

DOE is using appropriate parameters 

in dose calculations. Also see checklist 

items 7-10.

Sat

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

DOE uses conservative 

assumptions to estimate worst-case 

dose to a maximally-exposed 

offsite individual (DOE/WIPP 00-

3121, Rev. 4, Section 3.2).

Sat
14

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

DOE uses these exact values as 

exposure parameters (DOE/WIPP 

00-3121, Rev. 4, Section 3.2). The 

Annual NESHAP report CAP-88 

output file demonstrates that DOE 

is using these parameters in dose 

calculations.

Sat

Emissions and Environmental Monitoring -

Air

EPA Citation Comments (Objective Evidence) Result
15

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))

Stations A and B use alternate 

methods approved by the 

Administrator, per Section 3.3(3) 

of this rule (Nichols 1994). See 

checklist items 25, 27.

Station C sampling was designed 

based on ANSI N.12-1969, Guide 

to Sampling Airborne Radioactive 

Materials in Nuclear Facilities 

from which Method 2 was derived 

(WP 12-RC.01, Rev. 9). 

DOE/WIPP 89-028, Section 1.3 

confirms that “guidance was taken 

from . . . the CFR Title 40, Part 60, 

Appendix A, Reference Methods” 

and describes testing to establish 

the velocity profile for Station C.

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))

DOE has implemented continuous 

air monitoring at WIPP, and does 

not need to consider this 

requirement. (DOE/WIPP-00-

3121, Rev. 4, Section 3.3, 3.3.1)

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))

Stations A and B use alternate 

methods approved by the 

Administrator, per Section 3.3(3) 

of this rule (Nichols 1994). See 

checklist items 25, 27.

Station C sampling was designed 

based on ANSI N.12-1969, Guide 

to Sampling Airborne Radioactive 

Materials in Nuclear Facilities 

from which Method 2 was derived 

(WP 12-RC.01, Rev. 9).

DOE/WIPP 89-028, Section 1.3 

confirms that “guidance was taken 

from . . . the CFR Title 40, Part 60, 

Appendix A, Reference Methods.” 

Sat

Emissions and Environmental Monitoring -

Air

EPA Citation Comments (Objective Evidence) Result
16

23

a

Does DOE demonstrate that the effluent stream 

is either “directly monitored continuously with 

an in-line detector capable of distinguishing 

relevant radionuclides,” or alternately 

“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))

Yes. DOE implemented the latter 

sampling option, and continually 

collects samples and flow rate data 

to demonstrate compliance with 40 

CFR 191 Subpart A. All sample 

filters are screened to determine 

that alpha and beta activity fall 

below set action levels, and are 

then submitted for analysis. As 

described in Section 3.3.3 of the 

Implementation Plan for Subpart 

A, DOE then uses periodic 

confirmatory measurements to 

demonstrate compliance with dose 

standards. Sections 3.5 and 3.3.5 

document relevant radionuclides at 

WIPP. (DOE/WIPP 00-3121, Rev. 

4) 

Sat

23

b

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.

Periodic sampling (grab samples) may be used 

in lieu of continuous sampling only with EPA’s 

prior approval. Such approval may be granted 

in cases where continuous sampling is not 

practical and radionuclide emission rates are 

relatively constant. In such cases, EPA expects 

grab samples to be collected with sufficient 

frequency so as to provide a representative 

sample of the emissions.”

EPA 402-R-97-

001 Section 3.1, 

Page 11, (2(ii))

As stated in checklist item 23a, 

DOE samples continuously. After 

they are found to be below 

screening levels, all samples found 

to be representative are composited 

for periodic measurements 

(typically monthly for Station A,

and quarterly for Stations B and 

C). This process is described by 

DOE/WIPP 97-2238, Rev. 10. The 

procedure Periodic Confirmatory 

Analysis, Reporting, and 

Compliance Activities (WP 12-

RE3004, Rev. 5) describes the 

criteria for confirming that a filter 

sample is representative, and 

documents how to report and 

handle a sample which does not 

meet these requirements. 

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 approved the method used?

EPA 402-R-97-

001

Section 3.1, Page 

12, (2(iii))

Attachment 1 to the QAPP for 

Sampling Emissions (WP 12-

RC.01, Rev. 10) documents both 

the requirements of Method 114, 

and where WIPP documentation 

reflects these principles.

Sat
17

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, A98-49, II-B3-12, EPA’s Approval 

letter (Nichols 1994) 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) 

documents how the shrouded probe 

was qualified for use at WIPP.

Sat

26 Does DOE’s quality assurance program meet 

the performance requirements described in 

Appendix B, 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, Rev. 10) Section 

1.0 documents DOE quality 

assurance requirements. These 

meet the requirements of 40 CFR 

61. See Checklist Item 24.

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(3)(i) 

to (3)(iv), Page 12 

At Stations A and B, DOE uses 

alternate methods per Section 

3.3(3) of the Subpart A Guidance 

(402-R-97-001). See checklist 

items 25 and 27. 

Single Point Representative 

Sampling with Shrouded Probes 

(LA-12612-MS) documents how 

the shrouded probe was technically 

qualified for use at WIPP. EPA’s 

Approval letter (Nichols 1994) 

documents DOE’s compliance with 

these criteria, and EPA’s approval.

Sat

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)) 

DOE/WIPP 00-3121, Rev. 4., 

Section 3.2 documents DOE’s 

compliance with this requirement.

All areas of a potential discharge 

are continuously sampled, although 

even in a worst-case accident 

scenario, 1% of the Subpart A dose 

limit is not expected to be reached.

This requirement is also discussed 

in Sections 1.0 and 2.0 of 

DOE/WIPP 97-2238, Rev. 10.

Sat
18

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 of the Periodic 

Confirmatory Measurement 

Protocol (DOE/WIPP 97-2238, 

Rev. 10) states that the selected 

analytes “constitute approximately 

98% of the dose due to the average 

source term for CH and RH 

wastes.”

Sat

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 formally approved this 

alternative method (Nichols, 1994).

Sat

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)) 

This is not applicable. DOE has no 

other points with a potential to 

release radionuclides. CH 

(DOE/WIPP-95-2065, Rev. 10) 

and RH (DOE/WIPP-06-3174, 

Rev. 0) Waste Documented Safety 

Analyses document these 

conclusions.

NA

32 Does DOE demonstrate that in evaluating 

whether emissions must be measured for a 

given release point, 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))

Stations B and C use pollution 

control equipment. However, 

because DOE has chosen to sample 

continuously at these locations, this 

requirement is not applicable.

Sat

Environmental Measurements EPA Citation Comments (Objective Evidence) Result

33 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

34 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))

Section 3.1(5) of EPA 402-R-97-

001 is not applicable. See checklist 

item 34.

NA

35 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))

Section 3.1(5) of EPA 402-R-97-

001 is not applicable. See checklist 

item 34.

NA
19

36 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))

Section 3.1(5) of EPA 402-R-97-

001 is not applicable. See checklist 

item 34.

NA

37 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))

Section 3.1(5) of EPA 402-R-97-

001 is not applicable. See checklist 

item 34.

NA

38 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

39 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, 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” (DOE/WIPP00-3121, 

Rev. 4). ASER Chapter 4 

demonstrates that DOE’s 

environmental program monitors 

other release points and critical 

receptor locations(DOE-WIPP 12-

3489).

Sat

Compliance Reporting EPA Citation Comments (Objective Evidence) Result

40 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.

The Annual NESHAP report 

demonstrates that DOE reports 

results yearly, and that those results 

fall below regulatory limits. For 

calendar year 2012, the calculated 

effective dose equivalent to the 

maximally exposed individual of the 

public was less than 1.00x10-5

mrem.

Sat
20

41 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 – see 

checklist item 41.

Sat

42 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

Yes. See checklist item 42. Sat

Notification of construction or modification.

43 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.

The Annual NESHAP Report 

includes a description of 

construction and modifications 

during each reporting period. None 

requiring advanced notice took 

place during 2012.

Sat

44 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.

Yes, this is accomplished by the 

Annual NESHAP Report. See 

checklist item 44.

Sat

Record Keeping

45 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
1

Attachment B

Table of Documents Reviewed

Documents Reviewed and Copies Received 

During Inspection

191.03 Subpart A Inspection Nov 2013

Citation Document Title Subject Matter Source

Legal and Technical Reference Documents

EPA 402-R-97-001 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. EPA 402-R-97-001, January 1997

"WIPP Subpart A Guidance," EPA

DOCKET A-92-56, 

Item II-C-2

Memorandum of understanding between EPA and 

DOE, September 29, 1994

Agreement states that although not required, DOE 

will implement NESHAPs Subpart H regulations at 

the WIPP site until closure.

DOE/WIPP

DOE/WIPP 93-043 Effects of Salt Loading and Flow Blockage on the 

WIPP Shrouded Probe, by Chandra, Ortiz, McFarland, 

August 1993, DOE/WIPP 93-043

Report discusses the impact of salt loading on 

shrouded probe performance.

DOE/WIPP

DOE/WIPP 89-027 Evaluation Of The Station B Effluent Monitoring 

System In The Underground Exhaust Ventilation 

System At The WIPP, Sept 1990, DOE/WIPP 89-027

Documents testing at WIPP to evaluate the ability of 

Station B to collect representative samples.

DOE/WIPP

EEG-60 The Influence of Salt Aerosol On Alpha Radiation 

Detection By WIPP Continuous Air Monitors, by 

Bartlett and Walker, Jan 1996, EEG-60, 

DOE/AL/58309-60

Reports impact of salt deposits on monitor 

efficiency.

DOE/WIPP

DOE/WIPP 89-026 Evaluation Of The Station A Effluent Monitoring 

System In The Underground Exhaust Ventilation 

System At The WIPP, DOE/WIPP 89-026, Sept 1990

Documents testing at WIPP to evaluate the ability of 

Station A to collect representative samples.

DOE/WIPP
2

Rodgers et al., 1994 Single Point Aerosol Sampling: Evaluation of Mixing 

and Probe Performance In A Nuclear Stack, by 

Rodgers, Fairchild, Wood, Ortiz, Muyshondt, 

McFarland, July 1994

Compares performance of ANSI isokinetic with 

shrouded probes at DOE faculties.

DOE/WIPP

PNL-10816 Generic Air Sampler Probe Test, by Glissmeyer and 

Ligotke, Nov 1995, PNL-10816

Test of isokinetic and shrouded probes at Hanford.

Tests show that shrouded probes deliver samples 

with significantly less particle-size bias.

DOE/WIPP

PNL-10148 Functional Requirements Document For Measuring 

Emissions Of Airborne Radioactive Materials, by 

Glissmeyer, Alvarez, Hoover, McFarland, Newton, 

Rodgers, Nov 1994, PNL-10148

States general functional requirements for system 

and procedures for measuring emissions.

DOE/WIPP

PNL-SA-25532 Changing Methodology For Measuring Airborne 

Radioactivity Discharges From Nuclear Facilities, by 

Glissmeyer and Ligotke, May 1995, PNL-SA-25532

Tests show single-point sampling (shrouded) probes 

are superior to ANSI style multiple-point probes.

DOE/WIPP

Nichols, 1994 EPA Shrouded Probe Approval. Letter from Mary 

Nichols to Raymond Pelletier, dated November 21, 

1994.

Allows DOE to use the shrouded probe as an 

alternative measuring procedure.

DOE/WIPP

LA-12612-MS Single-Point Representative Sampling with Shrouded 

Probes by McFarland and Rodgers, LA-12612-MS, 

August 1993

Describes shrouded probe testing requirements and 

test performed to qualify probe for use at WIPP.

DOE OSTI 

Document 

website.

McFarland, 1993 Air Sampling With Shrouded Probes At The WIPP Site, 

by McFarland, Sept 1993

Paper discussing the use of the shrouded probe at 

WIPP. Benefits of the shrouded probe are discussed.

DOE/WIPP

DOE Procedural Documents

WP 12-2, Rev 18 WIPP ALARA Program Manual, WP 12-2, Revision 

18, 7/13/13

Describes organization and responsibilities of 

ALARA committee and coordinator. 

DOE/WIPP 

12-RL.01, Revision 

18

Radiochemistry Quality Assurance Plan, 12-RL.01, 

Revision 18, 11/12/12

Describes the management policy and organizational 

structure, and QA requirement for radiochemical 

analysis.

DOE/WIPP
3

DOE/WIPP 00-3121, 

Revision 4

Implementation Plan for 40 CFR 191, Subpart A 

DOE/WIPP 00-3121, Revision 4, December 17 2012

Outlines program at WIPP to show compliance with 

40 CFR 191, Subpart A. 

DOE/WIPP 

DOE/WIPP 12-3489 

(replaces 11-2225)

Waste Isolation Pilot Plant Annual Site Environmental 

Report for 2011, DOE/WIPP 12-3489, Rev. 0 

September 2012

Results of the environmental monitoring program, in 

particular radiological measurements. 

DOE/WIPP 

DOE/WIPP 97-2238, 

Rev. 10

Periodic Confirmatory Measurement Protocol for the 

Waste Isolation Pilot Plant, DOE/WIPP 97-2238, 

Revision 10, January 2013

Used to explain the protocol used to perform 

periodic confirmatory measurements. 

DOE/WIPP 

DOE/WIPP 99-2194, 

Rev. 7

Waste Isolation Pilot Plant Environmental Monitoring 

Plan. DOE/WIPP 99-219, Rev 7, March 2012. 

DOE environmental monitoring plans at the WIPP 

site. Of particular interest: Section 4.0, Dose 

Calculations, and 5.0, Environmental Monitoring 

Program.

DOE/WIPP

DOE/WIPP-06-3174 

Rev 0, 03/06

WIPP RH Waste Documented Safety Analysis, Section 

3.4.1.4. DOE/WIPP-06-3174 Rev 0, 03/06

This selection verifies that the air pathway is the 

only pathway of concern at the WIPP for RH waste.

DOE/WIPP.

DOE/WIPP-95-2065 

Rev. 10, 11/06

WIPP CH Waste Documented Safety Analysis, Section 

3.4.1.4. DOE/WIPP-95-2065 Rev. 10, 11/06

This selection verifies that the air pathway is the 

only pathway of concern at the WIPP for CH waste. 

DOE/WIPP. 

IC041072, Rev 9 Calibration of Effluent Monitoring Skids A1, A2, A3, 

B1 and B2 Flow Instrumentation, Maintenance 

Procedure, IC041072, Revision 9 

Instructions for calibration of FAS skids A1, A2, 

A3, B1 and B2 flow instrumentation. 

DOE/WIPP 

IC041097, Rev 2 Calibration of Station C Flow Instrumentation, 

Maintenance Procedure IC041097, Revision 2

Instructions for calibration of Station C flow 

instrumentation. 

DOE/WIPP 

IC041098, Revision 

5

U/G Exhaust Mass Flow Measurement System for Fans 

700A, B & C, Maintenance Procedure, IC041098, 

Revision 5

Documents calibration verification test and 

alignment of U/G exhaust. 

DOE/WIPP

IC413000, Revision

6

Station B Mass Flow Measurement System, Loop 

41A001W2001, Maintenance Procedure, IC413000, 

Revision 6, 06/02/11

Documents calibration of Station B mass flow 

measurement system. 

DOE/WIPP 
4

PM364001, Revision 

1

Predictive Maintenance to Determine Station A Probe 

Pull Frequency, Maintenance Procedure PM364001, 

Revision 1

Determine recommended frequency of Station A 

probe inspections based on meteorological data.

DOE/WIPP 

PM364005, Revision 

11

Inspection and Cleaning of Station “A” Sample Probes 

Bldg. 364, Maintenance Procedure, PM364005, Rev. 

12, 

Documents steps to inspect and clean Station A 

probes. "Determination of Probe Condition" requires 

that salt buildup "at the probe inlet should be no

more than 2/3 of the area" and "blocking the shroud 

exhaust should be limited to no more than 1/3 of that 

area". Now Section 8.6 

DOE/WIPP 

2012 NESHAP 

Report

Annual Periodic Confirmatory Measurement 

Compliance Report for the DOE WIPP for Calendar 

Year 2012, submitted 6/18/2013

Annual NESHAP report. Includes report, and 

CAP88-PC Version 3.0 output file. Documents 

annual results.

DOE/WIPP 

WP 12-ER4903, Rev 

16

Radiological Event Response, Emergency Response 

Procedure, WP 12-ER4903, Revision 15, 5/10/11

Procedure documents actions to be taken by CMRO, 

FSO, and Radcon if a potential or actual radioactive 

release takes place. 

DOE/WIPP 

WP 12-ER4916, Rev 

1

Consequence Assessment Dose Projection, Technical 

Procedure, Rev 18, 10/5/12

Procedure for estimating the potential dose 

consequence from a release or suspected release of 

radioactive material, using Hotspot, NARAC, or 

hand calculations. 

WP 12-ER4916. Rev 

20

Consequence Assessment Dose Projection, Technical 

Procedure WP 12-ER4916, Revision 20, 11/26/13

Documents procedure for estimating the potential 

dose consequence from a release or suspected 

release of radioactive material. Reviewed for 

consistency with Rev.16

DOE/WIPP 

WP 12-HP1305, Rev 

11

Air Sampling Equipment, Technical Procedure WP 12-

HP1305, Revision 10, 2/19/13

Instructions for the operation of fixed air monitoring 

equipment. Attachment 2 documents flow rates and 

alarm set points.

DOE/WIPP 

WP 12-HP1306, Rev 

8

Canberra Alpha Sentry Continuous Air Monitor, 

Technical Procedure WP 12-HP1306, Revision 8, 

3/21/10

Instructions for operating the Canberra continuous 

air monitor equipment at waste revieving bays.

Includes daily check sheets.

DOE/WIPP 

WP 12-HP1307, Rev 

12

Portable Instrument and Portal Monitor Operability 

Checks, Technical Procedure, WP 12-HP1307, Revision 

12, 7/30/12

Instructions for operational checks of portable 

contamination instruments. 

DOE/WIPP 
5

WP 12-HP1308, 

Revision 4

Portable Alpha-6 Continuous Air Monitors, Technical 

Procedure WP 12-HP1308, Revision 4, 3/28/11

Instructions for operation of Portable Alpha-6 

continuous air monitor. 

DOE/WIPP 

WP 12-HP3500, 

Revision 19

Airborne Radioactivity - Technical Procedure 

WP 12-HP3500, Revision 19, 01/24/12

Technical procedure. Provides instructions for 

analyzing, reporting, and trending results of air 

samples. Att. 5 contains Guide for Station A Filter 

Counting for Re-Entry into the U/G. 

DOE/WIPP 

WP 12-HP3700, Rev 

4

Radiological Event Reporting, Management Control 

Procedure WP 12-HP3700, Revision 5, 2/7/13

Documents the first estimate of a possible release. DOE/WIPP 

WP 12-HP4000, 

Revision 7

Emergency Radiological Control Responses, 

Emergency and Alarm Response Procedure, WP 12-

HP4000, Revision 7, 3/27/13

Addresses radiological contamination events which 

require an immediate stop work order.

DOE/WIPP 

WP 12-RC.01, Rev 9 Quality Assurance Program Plan for Sampling 

Emissions of Radionuclides to the Ambient Air at the 

Waste Isolation Pilot Plant, WP 12-RC.01, Revision 9, 

8/14/13

QA program for sampling air emissions at WIPP.

Contains useful background information regarding 

the design and qualification of sampling systems at 

Stations A-D. 

DOE/WIPP 

WP 12-RE3002, Rev 

3

Radiological Engineering Off-site Air Sampling -

Technical Procedure WP 12-RE3002, Revision 3, 

12/13/10

Instructions for collecting and documenting LowVolume filter retrieval in response to a potential 

release. 

DOE/WIPP

WP 12-RE3003, 

Revision 6 

Radiological Release of Potentially Contaminated 

Materials, Waste, and Items - Management Control 

Procedure, WP 12-RE3003, Revision 5, 01/19/12

Instructions for evaluating materials, waste, and 

items which are to be released from the WIPP as 

non-radioactive material. 

DOE/WIPP

WP 12-RE3004, Rev 

5

Periodic Confirmatory Sampling, Reporting, and 

Compliance Activities, Management Control Procedure, 

WP 12-RE3004, Rev 5, 02/07/13

This procedure provides instructions for 

Radiological Engineers of the Radiological Controls 

Department to fulfill the requirements of NESHAPs. 

DOE/WIPP 

WP 12-RL1001, Rev 

11

Sample Tracking and Custody, Technical Procedure, 

WP 12-RL1001, Revision 11, 12/17/12

Instructions for documenting receipt and storage of 

samples in WIPP laboratory.

DOE/WIPP

WP 12-RL1002, Rev 

10

Alpha Spectroscopy System Operation, Technical 

Procedure, WP 12-RL1002, Revision 10, 2/21/12

Direction for calibrating and operating the Canberra 

Alpha Spectroscopy System as interfaced with the 

Genie 2000.

DOE/WIPP
6

WP 12-RL1008, Rev 

8

Establishing Gross Alpha and Gross Beta SelfAbsorption Curves, Technical Procedure, WP 12-

RL1008, Revision 8, 01/04/12

Instructions for preparing samples of known activity 

and known weight to generate self-absorption curves 

for each of the gas proportional counters.

DOE/WIPP

WP 12-RL1009, Rev 

5

Gross Alpha and Gross Beta Activity in Air Filter, Soil, 

Water, Sludge, and Biota, Technical Procedure, WP 12-

RL1009, Revision 5, 04/26/11

Guidance for rapidly performing a variety of 

screening matrices for both high and low activity 

Radionuclides.

DOE/WIPP

WP 12-RL1010, Rev 

10

Sample Preparation, Technical Procedure, WP 12-

RL1010, Revision 10, 7/22/10

Directions for preparing samples to determine 

activity of radionuclides.

DOE/WIPP

WP 12-RL1011, Rev 

12

Elemental Separation - Strontium 90, Technical 

Procedure, WP 12-RL1011, Revision 12, 11/07/11

Directions for performing elemental separation of 

strontium from samples.

DOE/WIPP

WP 12-RL1012, Rev 

9

Elemental Separation - Transuranic Products, Technical 

Procedure, WP 12-RL1012, Revision 9, 05/07/12

Describes method for elemental separation and 

purification of actinide isotopes in samples.

DOE/WIPP

WP 12-RL1013, Rev 

9

Sample Mounting, Technical Procedure, WP 12-

RL1013, Revision 9, 09/12/07

Directions for electrodeposition sample mounting 

and neodymium fluoride coprecipitation sample 

mounting of actinides in preparation for alpha 

spectroscopy counting.

DOE/WIPP

WP 12-RL1014, Rev 

8

Routine Laboratory Operations, Technical Procedure, 

WP 12-RL1014, Revision 8, 1/03/13

Instructions for routine laboratory operation. DOE/WIPP

WP 12-RL1015, Rev 

18

Canberra Alpha Analyst System Operation, Technical 

Procedure, WP 12-RL1015, Revision 18, 12/19/12

Directions for calibrating and operating the Canberra 

Alpha Analyst 32-chamber alpha spectroscopy 

system.

DOE/WIPP

WP 12-RL1016, Rev 

13

Operation of the Oxford Series 5 Gas Proportional 

Counter, Technical Procedure, WP 12-RL1016, 

Revision 13, 12/19/12

Guidance for the operation of the Oxford Series 5 

Gas Proportional Counter. Editoial changes and 

instructions for a power outage made since 2010 

inspection

DOE/WIPP

WP 12-RL1200, 

Revision 1

Plutonium-241 Analysis, Technical Procedure, WP 12-

RL1200, Revision 1, 10/13/11

Provides method for the analysis of Pu 241 in any 

matrix after preparation of the sample in accordance 

with WP 12-RL1012 and WP 12-RL1015.

DOE/WIPP
7

WP 12-RL1400, Rev 

10

Radiochemistry Laboratory Waste Management, 

Technical Procedure, WP 12-RL1400, Revision 10, 

05/26/11

Instructions for handling, management, and disposal 

of laboratory waste.

DOE/WIPP

WP 12-RL1550, 

Revision 12

Control of Radioactive Standards, Technical Procedure, 

WP 12-RL1550, Revision 12, 11/11/11

Instructions for labeling, maintaining inventory, 

dilution of standards, completing standard logbook 

for new standards received, expired standards, 

depleted standards, and recertification or standards. 

DOE/WIPP

WP 12-RL3002, 

Revision 9

Radiochemistry Laboratory Data Validation and 

Verification, Technical Procedure, WP 12-RL3002, 

Revision 9, 11/26/12

Instructions for performing radiochemistry 

analytical data verification and validation by 

radiochemistry staff.

DOE/WIPP

WP 12-RL3003, 

Rev. 12

Data Reduction and Reporting, Technical Procedure, 

WP 12-RL3003, Revision 10, 6/19/2013

Instructions for processing laboratory data from the 

time of sample receipt to the reporting of final 

results.

DOE/WIPP

WP 13-1, Rev 33 Nuclear Waste Partnership LLC Quality Assurance 

Program Description, WP 13-1, Revision 33, 4/1/13

Identifies Federal and industry quality standards, and 

sets standards for WIPP QA programs.

DOE/WIPP 

DOE/WIPP 99-3119, 

Rev 7

Compliance Monitoring Implementation Plan for 40 

CFR 194.14(b), Assurance Requirement, DOE/WIPP 

99-3119, Rev. 7, 04/12

Outlines monitoring activities at WIPP to 

demonstrate compliance with 40 CFR 191 and 40 

CFR 194.

DOE/WIPP

Work Order 

1202385C

411-S-105 Calibration Skid Flow Indication. Corrective 

action package. Provided 12/2/2013.

Used to verify calibration of Kurtz flowmeter on 

Station C.

DOE/WIPP

Work Order 

1203590C

411-S-105 Calibration Station C Skid. Provided 

12/2/2013.

Used to perform a calibration check/calibration 

adjustment of the Station C 411-S-105 Flow Control 

Valve.

DOE/WIPP

Documents Generated During Inspection

JPW-20131022-01 Inspection schedule and opening presentation slides DOE/WIPP

JPW-20131022-02 Work Order 1300125, Station D Flow meter calibration.2/08/13. 12 pages. DOE/WIPP

JPW-20131022-03 Work Order 1309099, Station D vacuum pump calibration. 9/17/13. 7 pages DOE/WIPP

JPW-20131022-04 Surface subsidence survey, Loop 7 map. 10/24/2013. DOE/WIPP

JPW-20131022-05 Station C calibration labels. Photos received 

11/27/2013.

DOE/WIPP