**1** 

### DOCKET NO: A-98-49

Item: II-B3-108



## Emplacement Inspection Report

EPA INSPECTION No. EPA-WIPP-7.08-22c

OF THE

WASTE ISOLATION PILOT PLANT

July 22 – 24, 2008

U. S. ENVIRONMENTAL PROTECTION AGENCY

Office of Radiation and Indoor Air Center for Waste Management and Regulation 1200 Pennsylvania Avenue, NW Washington, DC 20460

September 2008**2** Contents

**1.0 Executive Summary....................................................................... 4**

**2.0 Inspection Purpose and Scope.............................................................**  **5**

**3.0 Inspection Team, Observers and Participants........................**  **................... 5**

**4.0 Performance of the Inspection.............................................................**  **6**

**5.0 Waste Emplacement/WWIS...............................................................**  **8**

**6.0 Magnesium Oxide Backfill................................................................. 10** 

**7.0 RH Operation................................................................................. 12** 

**8.0 Comparison with Inventory limits.......................................................**  **....14**

**9.0 Summary of Results...........................................................................15** 

Attachments

**Attachment A – Inspection Plan......................................................... ..............16** 

**Attachment B – Number of Waste Containers Emplaced as of July 22,**  **2008.........**

**.............. ...............17** 

**Attachment C - Material Emplaced in WIPP as of July 22, 2008................................19** 

**Attachment D – WWIS Administration Status Display .........................................20** 

**Attachment E – Summary of MgO Safety Factor Calcula tions..............................**  **.....21**

**Attachment F – Room 3, Panel 4 MgO Safety Calculati ons for July 22, 2008 .............**  **..22**

**Attachment G – Procedures Examined...............................................**

**............ .....23** 

**Attachment H – Inspection Checklist............................................**

**.................. ...26** **3**

Tables

**Table A Inspection Participants............................................................ .... 6** 

**Table B Waste Containers Reviewed During Inspection**

**................................. .10** 

**Table C Emplace CPR Quantities as of July 25, 2008...**

**... ................................14** 

Figures

**Figure 1 Inspectors check pillar spacing of RH boreholes............**  **.......................7**

**Figure 2 Arrangement of disposed waste in a room ......**

**............... ....................8** 

**Figure 3 Typical RH and CH TRU Mixed Waste Disposal Configur**  **ation............... 9** 

**Figure 4 Photo of disposed waste in a room.........**

**....................................... .11** 

**Figure 5 Emplaced CH waste in Room 3 Panel 4.................**

**..................... ......12** 

**Figure 6 Equipment prepared for RH waste emplacemen t in Room 2 of Panel 4.......13** 

**Figure 7 Emplaced RH Waste selected for review ........**

**........................ ...........13** 

**. 4** 

1.0 EXECUTIVE SUMMARY

**The U.S. Environmental Protection Agency (EPA or t he Agency) conducted an inspection of the U.S.**  **Department of Energy** = **s (DOE) Waste Isolation Pilot Plant (WIPP) near Car lsbad, New Mexico, from July**  **22 to July 24, 2008, in accordance with 40 CFR 194. 21. The WIPP is a disposal system for defense-rela**  **ted transuranic (TRU) waste as defined by the WIPP Land**  **Withdrawal Act. 1**  **EPA certified that WIPP complies with the Agency**  = **s radioactive waste disposal regulations (Subparts B and C of 40 CFR Part 191) on May 18,** 

**1998.**

**The purpose of this annual inspection was to determ ine if waste sent to WIPP during the past year has**  **been emplaced in the underground facility in the ma nner specified in DOE**  = **s Compliance Certification Application and other approvals. A specific focus**  **of this inspection was to review the site’s ability to**  **receive, process, and emplace contact-handled and r emote-handled TRU wastes within the repository, the**  **emplacement of magnesium oxide (MgO) backfill in ap propriate amounts to fulfill DOE commitments and**  **requirements, maintenance of relevant waste packagi ng records, including the electronic WIPP Waste**  **Information System (WWIS). EPA looked at selected activities, such as RH and CH waste processing, was**  **te emplacement activities, and record keeping.** 

**EPA concluded that DOE** = **s emplacement activities are adequate, that CPR is appropriately tracked and**  **recorded, that additional MgO is calculated properl y, and that MgO is emplaced properly. While DOE do**  **es not necessarily maintain an MgO safety factor above**  **1.67 for operational efficiency while loading wast e in a**  **room, DOE does place enough MgO before room closure is completed to assure that the safety factor is**  **maintained for each room. Though EPA has approved DOE’s request to reduce the MgO safety factor to 1**  **.2, the facility has not implemented any changes to the**  **MgO backfill procedure.**

**EPA did not identify any findings or concerns dur ing this inspection.**  **However, EPA does repeat the recommendation made in 2007: that DOE retain a phot**  **ographic record to verify the RH canister**

**identification number of the remote-handled caniste r as it is transferred from the transportation cask**  **to the facility cask and include the photographic record w**  **ith the permanent record package.**

**1 WIPP Land Withdrawal Act, Public Law 102-579, Secti**  **on 2(18), as amended by the 1996 WIPP LWA Amendment s,**  **Public Law 104-201. 5** 

2

**.** 0 INSPECTION PURPOSE AND SCOPE

**The purpose of this annual inspection was to deter mine if contact-handled (CH) and remote-handled**  **(RH) transuranic (TRU) waste sent to WIPP during th e past year has been emplaced in the underground**  **facility in the manner specified in DOE** = **s Compliance Certification Application and other ap provals. EPA**  **performed the inspection under authority of 40 CFR 194.21, which authorizes the Agency to inspect WIPP**  **during its operational period to verify continued c ompliance with EPA**  = **s WIPP Compliance Criteria and the certification decision of May 18, 1998. Emplacemen**  **t of waste and backfill, in particular, is relevant to**  **compliance because the emplacement method supports the models that DOE used in the WIPP performance**  **assessment. An additional purpose of this inspecti on was to verify that RH waste is emplaced in accor**  **dance with the plan and procedures specified in the Compl**  **iance Certification Application (CCA) and demonstra ted**  **during the WIPP RH startup inspection of January 9 – 11, 2007.** 

**Activities within the scope of this inspection inc luded: demonstration of the WIPP site’s ability to**  **receive, process, and emplace CH and RH TRU wastes within the repository, the use of magnesium oxide**  **(MgO) backfill in amounts to fulfill certification requirements and other approvals, maintenance of re**  **levant waste packaging records, including the electronic W**  **IPP Waste Information System (WWIS) and the verification of appropriately implemented quality a**  **ssurance practices. The review and examination of the**  **documents related to these processes was an importa nt part of the inspection.** 

**The WIPP site is operated by Washington TRU-Soluti ons (WTS) under contract to DOE. The**  **majority of waste related activities onsite are des cribed by or controlled through WTS procedures. A**  **list of WTS procedures examined for this inspection is prov**  **ided in Attachments G.**

3.0 INSPECTION TEAM, OBSERVERS, AND PARTICIPANTS

**The inspection team consisted of three EPA staff. Jody Johnson, Steve Holmes and Thomas**  **Kesterson of the New Mexico Environmental Departmen t and Jerry Fox and Chris Timm of Pecos**  **Management Services also observed the inspection ac tivities. A partial list of inspection participan**  **ts is provided in Table A** **6** Table A Inspection Participants

4.0 PERFORMANCE OF THE INSPECTION **The inspection took place on July 22 - 24, 2008, at DOE’s Carlsbad Field Office (CBFO) and at the**  **Waste Isolation Pilot Plant (WIPP) facility, which is located approximately 26 miles south east of Car**  **lsbad, New Mexico. The opening meeting with CBFO and WTS**  **personnel was held on the morning of July 22, 2008. Several DOE and WTS staff presented informat**  **ion addressing program status, updates and changes since the last EPA emplacement inspection in 2007:**  **primarily CH-RH waste processing, MgO emplacement and waste record keeping.** 

**The EPA inspectors accompanied CBFO and WTS person nel into the underground repository on the**  **morning of July 23, in order to examine waste packa ges and MgO that had been emplaced in Panel 4.**  **Inspectors selected several containers and recorded their numbers (see Figure 5 for container location**  **s); the**

**records for these containers were examined later in the WWIS computer database to verify correct waste**  **information is recorded by DOE. The WTS personnel explained how waste packages are handled, emplaced,**  **and answered EPA questions.**

INSPECTION TEAM

MEMBER POSITION AFFILIATION

**Chuck Byrum Inspector EPA ORIA**

**Tom Peake Inspector EPA ORIA**

**Nick Stone Inspector EPA Region 6**

CBFO / WTS PERSONNEL

**Art Chavez WRES** 

**Randy Britain WTS** 

**Dave Kump WTS** 

**Dave Speed WTS** 

**John Vandekraats WTS** 

**Mike Strum WWIS** 

**Ed Flynn WTS** **7** Figure 1 **Inspectors check pillar spacing of RH boreholes**

**In Room 5 Panel 4 inspectors observed the planning and arrangement of boreholes drilled (BH 044,**  **BH 097) to emplace RH containers. Measurement of b orehole spacing was checked to confirm appropriate**  **spacing of RH waste emplacement in the pillars. (Fi gure 1).** 

**The inspectors examined waste emplacement operatio ns in the underground and waste that had been**  **recently placed in the repository. The inspectors also reviewed records documenting that waste emplac**  **ement and MgO tracking were conducted in accordance with**  **procedures. To date, the waste received at the repository are contact-handled (CH) transuranic was**  **tes from Argonne National Laboratory-East (ANL-E) i n**  **Illinois, Los Alamos National Laboratory (LANL) in New Mexico, Idaho National Laboratory (INL),**  **Hanford Site in Washington, Rocky Flats Environment al Technology Site (RFETS) in Colorado, Savannah**  **River Site (SRS) in South Carolina, and the Nevada Test Site (NTS) in Nevada. These wastes are in sev**  **eral configurations: Standard Waste Boxes (SWBs), 55-ga**  **llon drums assembled in groups of seven called a Seven Pack, 100 gallon drums for supercompacted was**  **te, and Ten Drum Overpacks (TDOP). RH wastes are currently shipped to WIPP from INL.** 

**Inspectors reviewed the procedures with WWIS data administrators. Mike Strum (data administrator)**  **generated various reports for the inspectors at the Carlsbad Field Office. These included Shipment Sum**  **mary Reports, Waste Emplacement Reports and Waste Contai**  **ner Data Reports for RH and CH waste. 8**  Figure 2 **Figure 2 Illustrates the arrangement of disposed w aste in underground.**  **Represented are stacks of seven-packs of drums and standard waste boxes.** 

5.0 WASTE EMPLACEMENT/WWIS

**The repository is subdivided into panels, each pane l consisting of seven rooms. At the time of the**  **inspection, CH waste was being emplaced in Room 3 o f Panel 4. Waste containers are stacked in column**  **s (waste stacks) combining SWBs, drum packs, and TDOP**  **s (see Figure 3, 4, and 5). TDOPs are always placed on the floor of the room, occupying the bott**  **om and middle position of a waste column. SWBs and drums are emplaced in no particular order with most**  **wastes emplaced as received. The waste columns ar e in**  **a series of staggered rows, with a row consisting o f three columns that span the distance of a disposa**  **l room from left to right (Figure 2 and 3). Remote-handle**  **d waste is placed in the walls on eight foot center s**  **(Figures 1, 3, 6, and 7). 9**  Figure 3

Typical RH and CH TRU Mixed Waste Disposal Configu ration**10**

**While underground in Room 3, Panel 4, EPA inspector s selected recently emplaced waste packages**  **for review. The inspector read the shipment identi fication numbers directly off the emplaced containe**  **rs (See Figure 5 for CH locations). The containers selecte**  **d are identified in Table B below.**

Table B

**Waste Containers Reviewed During Inspection (Panel 4, Room 3)** 

**CH Waste (Field verified)**

**Site of Waste Container Origin**  **Identifier Container Type**  **Hanford RL080039 Ten Drum Overpack (TDOP) INL BN10185734 55-gallon drum**  **INL BN10196388 55-gallon drum**

**RH Waste (Panel 4, Room 3) Waste Emplacement Report and Container Data Report** 

**Site of Waste Container Origin**  **Identifier Borehole Number** 

**ANL-E ID0155 083**

**ANL-E ID0152 084**

**EPA inspectors examined reports from the following WIPP Waste Information System (WWIS)** 

**modules:**

**• Characterization Module, linked to the Waste Cont ainer Data Report**  **• Certification Module, linked to the Acceptance/Re jection Report**  **• Shipping Module, linked to the Shipment Summary R eport**  **• Inventory Module, linked to the Nuclide Report, W aste Emplacement Report and the MgO safety factor**  **calculation on the Emplace Containers Underground ( Attachments G).** 

**All records were found to contain the required inf ormation. EPA recommends that a permanent**  **photographic record of the RH canister number be pl aced in the RH record package to enhance traceabili**  **ty and ensure that correct containers are processed.** 

6.0 MAGNESIUM OXIDE BACKFILL

**Magnesium oxide (MgO) is used in the repository as backfill, as specified in DOE’s Compliance**  **Certification Application (CCA). EPA requires DOE to maintain an MgO safety factor to assure adequate**  **MgO to be chemically available to control the chemi stry of the room. EPA approved lowering the requir**  **ed safety factor to 1.2 from 1.67 in a letter dated Fe**  **bruary 11, 2008. At the time of the inspection, DO E was**  **using the old safety factor of 1.67 or greater, whi ch means that MgO in amounts of at least 1.67 times**  **the 11** 

**amount of carbon will always be in the repository t o control chemical conditions and remove carbon dio**  **xide**

**gas. WTS Technical Procedure WP 05-WH1011,**  CH Waste Processing, **Sections 5.0, 6.0 and Attachment 1 (CH Waste Processing Data Sheet), details steps g**  **uiding MgO placement and the required documentation to assure that MgO placement has been accomplished**  **correctly. Section 6.2 of WP 05-WH1011 states the Waste Handling Engineer (WHE) is to verify that the**  **safety factor is greater than or equal to 1.67. Attachments to WP 05-WH1011 record the quantity and**  **location of emplaced MgO for later entry into the**

**WWIS waste database.**

**Checklist items 4, 6, 7 and 12 specifically relate to MgO management and demonstrate that DOE has**  **an appropriate process for ensuring that MgO is pro perly emplaced. In addition to the requirement in**  **WTS**

**Technical Procedure WP 05-WH1011**

, **DOE addresses the addition of MgO in the WIPP Was te Handling**  **Operations WWIS User's Manual, WP 05-WH.01, Rev. 2, Attachment 1 - Special Requirements for**  **Additional MgO.**

Figure 4 **. Photo of disposed waste in a room.**

**DOE is emplacing waste stacked 2-3 containers high topped with MgO Supersacks. Figure 4 shows all**  **container types being shipped to date. Large drums are Ten Drum Overpacks (TDOPs), black barrels are**  **100-gallon drums with supercompacted waste, standar d waste boxes, and standard 55-gallon drum 7-packs.** **12** Figure 5 **Emplaced CH Waste in Room 3 Panel 4**

7.0 RH Operation

**The first shipment of RH waste was received on Janu ary 23, 2007 and was emplaced on January 28,**  **2007. As of our inspection, DOE has emplaced 161 RH canisters. The inspectors identified two**  **emplacements Boreholes 83 and 84 and reviewed the W WIS documentation to confirm appropriate transfer**  **and emplacement.**

**EPA reviewed various aspects of RH waste “operatio nal MODES” (“MODES are established to**  **provide a safe, structural approach to facility ope ration”, DOE /WIPP-06-3178, page 1-7). These includ**  **e RH Waste handling, RH Waste Storage and RH Standby Mod**  **es. EPA’s review included surface RH processing operations conducted prior to emplacement of the RH**  **container in the underground boreholes and underground RH processing activities. EPA reviewed**  **the requirements associated with these processes a nd**  **found them adequate. 13**  Figure 6 **Equipment prepared for RH waste emplacement in Room 2 of Panel 4** 

Figure 7 **Emplaced RH Waste selected for review 14** 

8.0 COMPARISON WITH INVENTORY LIMITS

**EPA has established limits for certain waste compo nents at WIPP by approving performance**  **assessment inventory estimates. Some limits, such as for iron and other metals, are minimum limits.**  **The**

**amount of iron and steel are now at 5.40 x 10 6**  **kg. The minimum limit is 2 x 10 7**  **kg iron. With total metals**

**at 5.7 x 10 6**  **kg, the WIPP is approaching 29% of the minimum amo unt stipulated in the certification.** 

**Other waste component limits are maximum limits. Of special concern is the maximum limit on the**  **total amount of cellulosic, plastic and rubber (CPR ) materials. In the CCA, DOE estimated the limit fo**  **r CPR**

**was 2.2 x 10 7**  **kg and this is the limit EPA has required DOE to m eet. However, in the subsequent**  **performance assessment baseline calculations, DOE a dded packaging materials to the calculations, and n**  **ow the CPR limit for WIPP is**  **2.4 x 10 7**  **kg (see Table C). CPR values are tracked on a per container basis and**  **the current CPR values as of July 21, 2008 are list ed in Table C.** 

**As of this inspection the WIPP contained almost 3. 7 x 10**  **6 kg of CPR in waste and 1.3 x 10**  **6 kg of**  **CPR in packaging material. In addition emplacement CPR, such as the slipsheets used to aid the**  **emplacement of the containers accounts for another 0.3 x 10**  **6 kg of CPR. This is a total of nearly 5.3 x 10**  **6 kg**  **of cellulosic, plastic and rubber material. Most of this is split between the cellulosic and plastic m**  **aterials; the**

**mass of rubber materials now account for about 5% o f the total mass of CPR, compared to 4.7% in 2007 a**  **nd 7% in 2006. Thus, the WIPP has achieved 24% of the**  **CPR limit.**

Table C Emplaced CPR Quantities as of July 21, 2008 **(Source: Opening Meeting Handout)**

Waste CPR: Emplacement CPR: **Type Weight (kg) Type Weight (kg)**

**------------------------------------ ------------ --------------------**  **Cellulosic 1,313,319 Cellulosic 44,316 Plastic 2,113,183 Plastic 256,898**  **Rubber 252,777**
**Total 3,679,279 (kg) 301,214 (kg)**

Packaging CPR: **Type Weight (kg)** Grand Totals: **Cellulosic 831,646 Cellulosic + Plastic = 5,077, 229**  **Plastic 517,867 Rubber = 252,777**  **Total 1,349,513 (kg) 5,330,006(kg) 15** 

9.0 SUMMARY OF RESULTS

**The inspectors reviewed emplacement operations and associated documentation for selected**  **containers. EPA concluded that DOE’s emplacement a ctivities are adequate, that CPR is appropriately**  **tracked, the safety factor is calculated properly, additional MgO is added as needed, and that all MgO**  **is emplaced properly. DOE noted that the current safe**  **ty factor was above the mandated 1.67 for closed ro oms**  **since the tracking officially began with Room 1, Pa nel 2 and Room 7, Panel 3 at the time of the inspec**  **tion (see Attachment E).** 

**The surface processing of RH and the underground o peration of RH container emplacement were**  **reviewed and found to be adequate according to spec ified plans documented in the CCA. EPA did not**  **identify any findings or concerns during this inspe ction. However, EPA recommends again that DOE**  **maintain a permanent photographic record of the RH canister number as it is removed from the**  **transportation cask. 16**  Attachment A July 22-24, 2008 Emplacement Inspection Plan

Purpose: **The purpose of this inspection is to determine if waste sent to WIPP during the past year has been**  **emplaced in the underground facility in the manner specified in DOE’s Compliance Certification Applica**  **tion and other approvals. The objective evidence is the**  **documentation that EPA can use to verify that DOE is**  **conducting its operation appropriately.**

**EPA is performing this inspection under the author ity of 40 CFR 194.21, which authorizes the**  **Agency to inspect the WIPP during its operational p eriod to verify continued compliance with EPA’s WIP**  **P Compliance Criteria and the certification decision**  **of May 18, 1998.**

Scope: **The scope of this inspection includes: demonstrati on of the site’s ability to receive, process, and**  **emplace contact-handled and remote-handled TRU wast es within the repository, the use of magnesium oxid**  **e (MgO) backfill in appropriate amounts to fulfill DO**  **E commitments and requirements, maintenance of relevant waste packaging records, including the ele**  **ctronic WIPP Waste Information system (WWIS) and th e**  **verification of appropriately implemented quality a ssurance practices. The availability of documentat**  **ion of these processes and activities will be a major sour**  **ce of review.**

Focal Areas for this Year’s Inspection:

**- What changes have taken place to emplacement activi**  **ties and documentation since last year’s inspection.** 

**- What changes have taken place to MgO emplacement si**  **nce EPA’s approval of decreased MgO.**

Location: **The inspection will be held at the DOE’s WIPP faci lity located twenty-six miles southeast of**  **Carlsbad, New Mexico and the Carlsbad Field Office (CBFO). Inspection activities will include**  **examination of the underground facilities, review o f records related to waste emplacement, and other** 

**information as needed.**

Duration: **The EPA expects to complete its inspection in abou t two days plus an initial meeting. Each full day**  **will begin with an opening meeting at 8:00 a.m. and end no later than 5:00 p.m. with a closeout sessio**  **n.**

Expected Date: **Week of July 21, 2008**

Documents For Review: **Electronically provide for this inspection the lat est version of pertinent documentation and/or**  **procedures related to CH and RH waste emplacement, MgO, WWIS, training, etc.** **17** Attachment B

**Number of TRU Waste Containers Emplaced at WIPP as of 07/22/2008** 

**Contact Handled Waste**

**Site**

Container Type 100

gallon 55

gallon Pipe

overpack S100 Std

Waste

Box TDOP 85 gallon

overpack 2008

total 2007

total 2006

total

**ANL-E 0 318 0 0 0 12 0 330 334 334** 

**RL 0 6712 2163 0 350 249 0 9474 7390 6159** 

**INL 13434 17785 0 0 1845 2207 0 35271 30722 23564** 

**LANL 0 7409 314 104 577 1 0 8405 7046 5040** 

**LLNL 0 678 0 0 2 0 0 680 688 688**

**NTS 0 1805 0 0 14 0 0 1819 1827 1827** 

**RFETS 0 15460 21174 0 3910 4 0 40548 40548 40548** 

**SRS 0 3171 0 0 587 2127 0 5885 4755 4173** 

**WIPP 0 2 0 0 0 0 2 4 3090 3006** 

TOTAL 13434 53340 23651 104 7285 4600 2 102416 96929 8586 8**18** Attachment B (continued)

**Number of TRU Waste Containers Emplaced at WIPP as of 07/22/2008** 

**Remote Handled Waste**

**Site** 2008

Total

**ANL-E**

**RL**

**INL 161 161** 

**LANL**

**NTS**

**RFETS**

**SRS**

**WIPP**

TOTAL 161 161

**NOTE: The drums listed for WIPP consist of two drum s of site generated waste, two drums from RFETS tha**  **t were overpacked on site, with primarily empty dunnage drums but wit**  **h some salt-filled dunnage drums.**

**Argonne National Laboratory - East (ANL-E) Hanfo rd Site (Hanford)**  **Idaho National Engineering and Environmental Labora tory (INEEL) Los Alamos National Laboratory (LANL)**  **Lawrence Livermore National Laboratory (LLNL) Ro cky Flats Environmental Technology Site**  **(RFETS) Nevada Test Site (NTS) Savannah River Site (S**  **RS) Waste Isolation Pilot Plant (WIPP)** 

**Drums = 55 gallon (208 liter or 0.208 m 3**  **) steel drums Pipe Overpack = 55 gallon drum pip e**  **overpack except for the S100 SWB = Standard Waste Box TDOP = ten drum overp**  **ack Dunnage = inert drums used to complete waste assemb**  **lies 19**  Attachment C

**Materials Emplaced in WIPP as of July 22, 2008 (Table configuration modified for simplification)** 

**CH WASTE:**

**MP Material Type Material Description Material We ight (kg)** 

**1 Waste Iron base Metal Alloys 5,403,886.18 2 Waste Aluminum Based Metal /Alloys 38,821.4**  **8 3 Waste Other Metal/ Alloys 280,348.12**  **4 Waste Other Inorganic Materials 1,167,015.90 6 Waste Cellulosics 1,314,563.94**  **7 Waste Rubber 252,959.37 8 Waste Plastics 2,100,247.72**  **9 Waste Solidified Inorganic Material 5,857,381.2 6**  **10 Waste Solidified Organic Material 393,205.1 6**  **12 Waste Soils 19,270.68**

**13 Steel - Packaging Steel Container Materials 10,42**  **0,254.93**

**14 Plastic - Plastic /Liners Container Packaging Materials 518,142.96**  **15 Cellulosic - Cellulosic Packaging Packaging Materials 831,641.58**  **18 Emplacement Cellulosic Emplacement Material 44,331.05**  **20 Emplacement Plastic Emplacement 1,507,490.30**

**Material**

**RH Waste**

**1 Waste Iron Base Metal Alloys 12,785.19**

**6 Waste Cellulosics 1.90 8 Waste Plastics 14,427.00**  **13 Steel Steel Container Materials 83,237. 00**  **Packaging**

**14 Plastic Plastic/ Liners Container Packaging Materials 173.14**  **15 Cellulosic Cellulosics Packaging 4.26 Packaging Materials** 

**MgO**

**16 Emplacement Magnesium Oxide 19,078,590.11 18 Emplacement Cellulosic Emplacement Mat’l**  **39,185.10 20 Emplacement Plastic Emplacement Mat’l 44**  **,832.60 20**  Attachment D

Status of Waste Containers August 25, 2008**21** Attachment E **Summary of MgO Safety Factor Calculations**

MgO Waste CPR Safet y Panel Room (kg) (kg) (kg) Facto r

----- ----- ---------- ---------- ---------- ------ - 1 7 1,127,526 508,254 276,990 2.0 1
6 222,885 101,210 86,116 1.4 4
5 222,885 160,047 79,213 1.5 6
4 228,600 128,597 85,525 1.5 1
3 1,034,415 749,764 342,069 1.6 7
2 1,028,825 948,002 229,442 2.1 7
1 617,220 311,843 138,330 2.1 4

2 7 1,028,700 571,001 236,830 2.0 9
6 982,980 461,528 209,305 2.2 0
5 988,820 498,970 197,609 2.2 9
4 977,265 518,555 220,912 2.1 7
3 1,028,700 667,662 211,841 2.2 7
2 965,835 733,025 165,412 2.6 2
1 691,515 416,679 186,200 1.7 1

3 7 960,120 711,188 104,831 4.0 3
6 954,405 876,558 228,033 1.9 5
5 1,022,985 808,693 284,651 1.7 0
4 960,120 899,470 255,054 1.7 9
3 931,545 1,000,561 243,860 1.8 9
2 944,880 1,004,479 227,889 2.0 3
1 662,940 722,043 183,072 1.7 6

4 7 942,975 1,051,062 248,903 1.9 0
6 925,830 945,599 267,494 1.7 1
5 946,785 890,039 265,295 1.7 1
4 1,013,460 830,990 290,608 1.7 0
3 363,855 334,452 150,581 1.1 6
2 0 4,642 1,523 .0 0

=================================================== =**22** Attachment F **Room 3, Panel 4 MgO Safety Factor Calculation for A ugust 25, 2008** **23** Attachment G

Procedures Examined

**> NS-E2008-1:** CH Waste Processing **, Technical Procedure WP 05-WH1011, Revision 26; Ef fective**  **Date: March 28, 2007**

**> NS-E2008-2:** Waste Stream Profile Form Review and Approval Progr am **, WP 08-NT.03, Revision 8, October 18, 2006** 

**> NS-E2008-3 :** TRU Waste Receipt, Management Control Procedure, **WP 08-NT3020, Revision 16, Effective Date: November 5, 2007** 

**> NS-M2008-O :** WIPP Waste Information System User's Manual WWIS Ve rsion 5.4a **, DOE/CBFO 97- 2273, Rev. 15, May, 2008** 

**> NS-E2008-4:** WIPP Waste Handling Operations WWIS User’s Manual, **WP 05-WH1-01 Revision 3; Effective Date: February 11, 2008** 

**> NS-A2008-G:** WIPP Contact Handled (CH) Waste Documented Safety A nalysis **DOE/WIPP-95-2065, Revision 10, November 2006** 

**> NS-A2008-H:** WIPP RH Waste Documented Safety Analysis DOE/WIPP-0 6-3174, **Revision 0, March**

**2006**

**> NS-E2008-5:** WIPP RH Technical Safety Requirement DOE/WIPP-06-31 78, **Revision 0, March 2006**

**> NS-E2008-6: S**

pecification for Prepackaged MgO Backfill, **Specification, D-0101, Revision 7, Revision Date: May 12, 2005** 

**> NS-E2008-7 : C** onduct of Operations **WP 04-CO, Revision 8, Effective Date: March 11, 20 08** 

**> NS-E2008-8 :** Horizontal Emplacement and Retrieval Equipment Asse mbly, Technical Procedure, **WP05-WH1700, Revision 6, Effective Date: April 30, 2008** 

**> NS-E2008-9 :** Road Cask Transfer Car Operation, Technical Procedu re, **WP 05-WH1701, Revision 9, Effective Date: October 31, 2006** 

**> NS-E2008-10 :** Facility Cask Transfer Car 41-H-003 Operation, Tech nical Procedure, **WP 05- WH1704, Revision 6, Effective Date: January 19. 200**  **6**

**> NS-E2008-11:** RH Canister Transfer System, Technical Procedure, **WP 05-WH1705, Revision 6, Effective Date: June 27, 2006** 

**> NS-E2008-12:** RH-TRU 72-B Trailer Unloading, Technical Procedure, **WP 05-WH1709, Revision 10, Effective Date: May 16, 2007** 

**> NS-E2008-13:** RH Processing 72-B, Technical Procedure, **WP 05-WH1710, Revision 10, Effective Date: May 16, 2007** **24**

**> NS-E2008-14:** RH–TRU 72-B Cask Operation, Technical Procedure, **WP 05-WH1712, Revision 2, Effective Date: August 1, 2006** 

**> NS-E2008-15:** Facility Cask and Facility Cask Rotating Device, Te chnical Procedure, **WP 05- WH1713, Revision 7, Effective Date: August 29, 2007** 

**> NS-E2008-16:** RH Cask Preparation Station 41-Z-076, Technical Pro cedure, **WP 05–WH1714, Revision 1, Effective Date: June 21, 2006** 

**> NS-E2008-17:** Cask Unloading Room Shield Door Operation, Technica l procedure, **WP 05–WH1717, Revision 6, Effective Date: August 23, 2006** 

**> NS-E2008-18:** CNS 10-160 B Trailer Unloading, Technical Procedure

, **WP 05–WH1718, Revision 5, Effective Date: February 27, 2007** 

**> NS-E2008-19:** 10-160 B RH Processing, Technical Procedure, **WP 05-WH1722, Revision 9, Effective Date: January 14, 2008** 

**> NS-E2008-20:** CNS 10-160B Cask Operation, Technical Procedure, **WP 05-WH1716, Revision 3, Effective Date: November 2, 2006** 

**> NS-E2008-21:** Surface RH Transuranic Mixed Waste Handling Area In spections, Technical
Procedure, **WP 05-WH1744, Revision 8, Effective Date: February 28, 2007** 

**> NS-E2008-22:** 10-160B Shielded Insert Installation and Removal, T echnical Procedure, **WP 05-**

**WH1752**

, **Revision 3, Effective Date: July 10. 2006**

**> NS-E2008-23:** RH Waste Handling Abnormal Operations, Technical Pr ocedure, **WP 05-WH1758, Revision 4, Effective Date: May 17, 2007** 

**> NS-E2008-24:** Categorization and Classification of Operational Em ergencies for RH Waste, Management Control Procedure **, WP 12-ER3905, Revision 2, Effective Date: June 25 , 2007** 

**> NS-A2008-BA:** Contamination Control **, WP 12-HP3400, Revision 5, Effective Date: Decembe r 17,** 

**2003**

**> NS-E2008-25:** Hazardous Material Spill and Release Response, Eme rgency Response Procedure, **WP12-ER 4902, Revision 11, Effective Date: June 25, 2007** 

**> NS-A2008-R:** Consequence Assessment Dose Projection **, WP 12-ER4916, Revision 11, Effective Date: February 27, 2008** 

**> NS-E2008-26:** Radiological Surveys, Technical Procedure, **WP12–HP1100, Revision 11, Effective Date: July 12, 2007** 

**> NS-E2008-27:** Contact Handled (CH) Technical Safety Requirements

, **DOE/WIPP-95-2125, Revision 10, Effective Date: November 2006** **25**

**> NS-E2008-28:** Radiological Posting and Access Control, **WP 12-HP1500, Revision 12, Effective Date: December 14, 2006** 

**> NS-E2008-29:** Abnormal Radiological Conditions, **WP 12-HP2001, Revision 3, Effective Date: August 23, 2006** **26** Attachment H 2007 EPA Emplacement Inspection Checklist

**#IIt #** Questions: Comments and Objective Evidence Results

Question: Waste Emplacement

**1 Is waste being emplaced in the underground facility in the**  **manner specified in DOE’s Compliance Certification/ Re** 

**Certification or other relevant**

**documentation? Yes for CH. Procedure WP 05-WH1011, Rev. 26, CH**  **Waste Processing, Steps 4 to 7, pages 25 through 29 describe the waste emplacement process. Visual**  **verification of the emplaced waste in Row 65 of Pan el**  **4, Room 3 was conducted.**
**Yes for RH. RH processing procedures for 72-B (WP 05-WH1710) and 10-160-B (WP 05-WH1722)**  **containers are consistent with the approach discuss ed** 

**in the CCA documentation. Satisfactory** 

**2 Are CH waste containers stacked**  **in columns appropriately given the type of container?**  **Yes, waste is being emplaced appropriately. Procedu re**  **WP 05-WH1011, Attachment 4, Waste Emplacement Report Data Sheet. The waste stacking arrangement**  **was verified during the inspection in Room 3 Panel 4.**  **Satisfactory**

**3 Are records adequate? Randomly**

**select three CH and two RH waste containers to verify records for**  **waste approval, shipment, and receipt.**  **Yes. TRU Waste Receipt WP 08-NT3020, Rev.16 describes the process. Records produced are Unifor**  **m Hazardous Waste Manifest, TRU Waste Receipt**  **Checklist, Shipment Summary Report, RH waste Processing Data Sheet, Radiological Survey Report,**  **and Waste Emplacement Report. CH waste produces comparable records. EPA reviewed records and found**  **the records to be adequate and traceable.**

**Selected Containers:**
**CH Waste - TDOP from Richland: RL080039, 55 gal drum from INL: BN10185734, 55 gal** 

**drum from INL: BN10196388 RH Waste – Borehole 83: ID0155 from ANL-E,** 

**Borehole 84: ID0152 from ANL-E Satisfactory** 

**4 Is DOE properly emplacing**  **backfill material (magnesium oxide [MgO]) with the waste**  **packages? That supersacks are placed on top of waste stacks**  **according to procedure? Yes. Procedure WP 05-WH1011, Rev. 26, CH Waste**  **Processing, Section 5.0, requires MgO to be placed on**  **each waste column. While underground the inspector s**  **observed that each waste column had a MgO supersack emplaced.**  **Satisfactory**

**5 Are RH boreholes closed properly?** 

**(Note also see #9 for tracking of RH in the U/G)**  **Yes, Correct borehole plug emplacement is described in 72-B RH Processing, WP 05–WH1710, Sections**  **19 and 20. Monitoring of smears is also described in**  **this document (Section 20.37). The inspector observed emplaced plugs.**  **Satisfactory 27** 

**6 Verify documentation for the**

**containers listed in item 3 - waste generator site transmittal of waste**  **to WIPP, WIPP approval, shipment certification for**  **transport to WIPP, shipment initiation documentation,**  **shipment received at WIPP records, waste emplaced in the**  **underground, and placement of backfill [MgO].**  **The inspector examined documentation related to selected containers. Inspectors verified that the**  **se records exist for these containers and determined t**  **hat the documentation is adequate.**  **Satisfactory**

**7 Is the acceptance of the MgO backfill material from the supplier** 

**documented? Yes. Record of MgO specification from the supplier**  **is available (see ????). The inspectors examined t hese**  **documents and found then to be adequate. Satisfactory** 

RH Waste Emplacement Questions

**8 Are RH containers approved for receipt, received, processed, and**  **emplaced properly? Yes. RH processing procedures for 72-B (WP 05-**  **WH1710) and 10-160-B (WP 05-WH1722) containers documents the WIPP requirements for processing RH** 

**containers. Satisfactory** 

**9 Are RH containers appropriately**

**tracked?**

**Where is the information?**

**--In the WWIS, what report**

**--During the receipt/transfer process where is it recorded?** 

**--In the underground? Yes. Container Numbers ID0152, and ID 0155**  **(Boreholes 083 and 084) were tracked for verificati on.**  **The Waste Container Data Report was generated from the WWIS. Container disposal was posted on the**  **underground disposal map. The container data report was generated by WWIS. WP 05-WH1710, Section**  **20.45 says to record RH emplacement location on underground map. 72-B Cask serial number, 72-B**  **Cask shipment numbers were verified and concur with**

**WWIS. Satisfactory** 

**10 Content of RH canisters**

**--pick 1 to 3 canisters Borehole 083, container number ID0152,** 

**Borehole 084, container number ID0155**

**Waste Container Data Reports for these were generated by WWIS and EPA verified them.**  **Satisfactory**

**11 Volume and mass and/or concentration of important waste**  **components and radionuclides (RH and CH)?** 

**Are they within statutory and regulatory limits?**  **Waste Container Data Report showing detailed description of nuclide information for the selected**  **containers were generated and verified by the inspectors.** 

**Yes Satisfactory** **28**

Question: Procedure

**12 For the MgO needed for high CPR, are there procedures or** 

**documentation for the WHE or WHM (or other appropriate**  **personnel) identifying** when **and**

where **additional MgO is needed? In the WIPP Waste Handling Operation WWIS User’s**  **Manual, WP 05–WH.01, Revision 3, 2/11/08, Attachment 1 – special requirements for additional**  **MgO are discussed and CH Waste Processing, WP 05- WH1011 Section 5.0-NOTE, states that the WHE will**  **calculate the safety factor (SF) at the end of each shift** 

**and that the WHM must be notified if the SF is belo w**  **1.67. EPA verified that this process is performed. Satisfactory** 

**13 Is there documentation that**

**identifies** how **the MgO should be placed with high CPR waste?**  **Yes. Section 5.2 of WP 05-WH1011 requires that additional supersacks are to be placed in the waste**  **stack if the WHM determines that it is required. Satisfactory** 

**#** Question **:** Records/WWIS

**14 Does the WWIS adequately**  **document waste shipment and emplacements information for** 

**waste containers selected item 3 above? CH, RH**  **Yes. In the Waste Emplacement Report, the WWIS adequately documents waste shipment and**  **emplacement information. WWIS Waste Emplacement Reports, WWIS Waste Container Data**  **Report contain container number, shipment number, emplacement information in the underground. These**  **data were verified for waste containers by the inspectors.**  **Satisfactory**

**15 Is DOE maintaining records of waste shipments and**  **emplacement properly? CH, RH Yes, WWIS Reports (Waste Container Data Report,**  **Emplacement Report, RH Receipt) and underground maps verify that records are properly maintained fo**  **r both CH and RH waste containers.**  **Satisfactory**

**16 Do the characterization module, certification module, shipping**  **module, and inventory module adequately record the required** 

**information? Yes. DOE staff queried the WWIS for this**  **information and demonstrated (via Waste Container Data Reports, and Shipment Summary Reports) that**  **they adequately recorded the required information. WP 05-WH.01, WP 05-WH1729, WP 08-NT3020**  **describe the procedures for recording of data. The inspectors examined five waste containers, three CH**  **and two RH, documents to verify that this informati on**  **is adequately recorded. Satisfactory** 

**17 Characterization Module -**

**Review a WWIS Waste Container Data Report. Does this report**  **adequately record the Waste**

**Stream Profile Form information? Yes. WWIS staff generated the Waste Container Data**  **Reports for the selected containers. These reports**

**contain Waste Stream Profile information for each container. The inspectors verified that this modul**  **e contains this information.**  **Satisfactory**

**18 Characterization Module - Does the data administrator verify that**  **DOE/CBFO has granted certification and transportation**  **authority to the generator/shipper site prior to review of**  **generator/shipper characterization**

**data? Yes. The Waste Stream Profile Form Review and**  **Approval Program, WP 08-NT.03, Section 8.4 documents that “...allows DA (data administrator)**  **approval of certified container data prior to shipm ent**  **of containers...”. The inspectors verified these approvals.**  **Satisfactory 29** 

**19 Shipping Module - Review the**  **Shipment Summary Report. Does the report correctly record the**  **containers shipped? CH, RH Yes. The inspectors examined the Shipment Summary**  **Reports for the selected containers and verified th at**  **each report contained the correct containers. Satisfactory** 

**20 Inventory Module - Review the Waste Emplacement Report.**  **Does this report adequately record the date of receipt, and disposal**  **locations of containers? CH, RH Yes. The Waste Emplacement Report (WER) records**  **contain the container number, shipment number, emplacement data and underground location. The**  **inspectors verified that the WER recorded the information adequately.**  **Satisfactory**

**21 Is MgO implementation appropriately documented?** 

**Where is it described?**

**Does the WWIS properly track MgO emplaced quantity and** 

**location?**

**Where is this described? Yes. Procedures WIPP Waste Handling Operations**  **WWIS User’s Manual, WP 05-WH.01, Section 6.2.5 and CH Waste Processing, WP 05-WH1011, Section** 

**5.0 and Attachment 6 describe and documents the process. MgO information is input by the WHE into**  **the WWIS computer database in the Emplace Containers Underground screen as documented in WP**  **05-WH.01, Section 6.1. Processing of released shipments, emplacement of processed containers and**  **emplacement of MgO on completed stacks are done as described in WP 05-WH1011. The inspectors verified**  **that MgO emplacement is appropriately implemented and tracked properly.**  **Satisfactory**

**22 Is DOE properly tracking the MgO backfill so that the MgO**  **safety factor can be accurately**

**calculated? Yes. As noted in Q-21, above, procedures WP05-**  **WH.01, Attachment 1 and WP 05-WH1011 show that MgO tracking is adequate.**  **Satisfactory**

**23 Is DOE assuring that the 1.67 safety factor being maintained on** 

**a room basis?**

**What methodology (equations) are being used to calculate the**  **safety factor? Yes. Procedure WP 05-WH1011, Rev 26, CH Waste**  **Processing Section 5.0 states that the safety facto r of** 

**1.67 must be maintained. In a letter dated Februar y**  **11, 2008, EPA altered the safety factor requirement to**  **1.2. DOE has not altered its procedures to reflect the**  **new safety factor and maintains a safety factor of 1.67**  **at the time of the inspection. Satisfactory** 

**24 Does the WWIS accurately calculate the 1.67 safety factor**  **and recommend the proper amount of MgO to emplace?** 

**Where has this been verified? Yes. This is performed on a regular basis. WIPP**  **Waste Handling Operations WWIS User’s Manual , WP 05-WH.01, Section 6.2.5 and Attachment 1**  **describes the steps. The Software Validation Test, MgO Emplacement process and Safety Factor**  **Calculation Revision 0, March 2, 2005 documents the testing of the new modules added to WWIS to track**  **MgO and calculate the safety factor on an ongoing basis room by room. The inspector verified that**  **this approach has not changed.**  **Satisfactory**

**25 Is there documentation that** 

**describes how the site will use and implement the MgO module** 

**of the WWIS? Yes. WIPP Waste Handling Operations WWIS User’s**  **Manual, WP 05-WH.01, Section 6.2.5 notes that the waste handling engineer is to input MgO data into t**  **he WWIS. The MgO safety factor calculation is done**  **routinely as described in WP 05-WH.01, Attachment 1. The inspector verified this activity.**  **Satisfactory**