### DOCKET NO: A

- 98

- 49 Item: II

- B3

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## 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 201 4

### 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 it s continued oversight program. This inspection was conducted under the autho r ity 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 w aste disposal operations and any unplanned or accidental releases that might occ ur 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 we re 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 radi ation 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, th e handling of samples, and the generation analytical res ults by the WIPP laboratory. This inspection was conducted under the authority of 40 CFR 191, Subpart A.

3.0 Inspection Team, Observers, and Participants

Th e 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 la boratory activities. Site staff discussed changes in the program since the las t 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 shroud ed probe at Station A, Skid A

1, 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.

- Fl ow 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 f

rom 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 pro cedures 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 aer osol 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 S kid A

- 1 confers several advantages to the program. The most reliable sampling points, Skids A

2 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 mi ning 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 duri ng 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

, a n exterior weld on the transfer line supporting the probe was observed to have cracked. The transport line has be en 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 out side view as found Shroud out side view as found Shroud out side 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 cal ibration 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 fo r 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 verifi ed was provided to EPA on November 27 and Dec 2 ( JPW

20131022

- 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 previou s 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 u seable, and to allow initial doe s 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. 1 9 , 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 calibr ation 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
emergenc y 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 Summ ary 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 pub l ic 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 Guid ance (402

- R

- 97

- 001). Based on the inspection activities document ed 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 pot entia l 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 e xposed 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 o r 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 dur ing the last reporting period. This inspection is conducted under the author ity of 40 CFR 191, Subpart A. This inspection is part of EPA’s continued oversight to ensure that WIPP can, during the operational pha se 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 th e 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 Wa ste (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 samp ling 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 con ditions 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 potent ial release during operations. Describe the proc ess 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 mile s 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.

In spection Dates : October 22

- 24, 2013.

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

I nspection 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 exce ed 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 a ssure 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

- R

97

- 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

- R

97

- 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 Wast e 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

- R

97

- 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

- R

97

- 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 expo sure 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

- R

97

- 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 gr oundwater surveillance, biota sampling and off

site 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

- 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

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

- R

97

- 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 cons idered. 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 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

- R

97

- 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

- R

97

- 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

- R

97

- 001 Section 2.7.1, Page 8 Yes. The effective dose equivalent and

table of organ dose equivalents is includ ed 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

- R

97

- 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

- R

97

- 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 r eleases. Sat

14 Does DOE use CAP88

- PC to perform dose calculations? EPA 402

- R

97

- 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

- R

97

- 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 adeq uately support exposure parameters used in dose calculations? EPA 402

- R

97

- 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

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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 DOE uses these exact valu es 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 Airbo rne 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 S ection 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 implement ed 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 tha t “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 fi lters 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 demo nstrate 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
samp le 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
t he 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”? E PA 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’ 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 WI PP. 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 accordi ng 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 ap proval 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 equivale nt 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 sa mpled, 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

- 2 238, 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 Analyse s document these conclusions. NA

3 2 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)) S tations 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

3 3 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

3 4 Does DOE demonstrate that air at the point of measurement is continuously sampled for collection of radio nuclides 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

3 5 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

3 6 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

3 7 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

3 8 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). AS ER 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

4 0 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 201 2, the calculated effective dose equivalent to the maximally exposed individual of the public was less than 1. 00 x10

- 5

mrem. Sat

### 20

4 1 Does DOE report results of monitor ing 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

4 2 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.

4 3 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

r equiring advanced notice took place during 201 2

. Sat

4 4 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

4 5 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

Rodger s 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 meas uring 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 pa rticular 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, Revisio n 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 Oper ability

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

- HP13 08, 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 Low

Volume 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 Self

Absorption 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

- RL1 009, 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, R evision 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,

Techni cal 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 fina l 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 p erform a calibration check/calib ration 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