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 Calculations...................................21 

Attachment F – Room 3, Panel 4 MgO Safety Calculations 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 Configuration...............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 emplacement 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 the Agency) conducted an inspection of the U.S. 

Department of Energy=s (DOE) Waste Isolation Pilot Plant (WIPP) near Carlsbad, New Mexico, from July 

22 to July 24, 2008, in accordance with 40 CFR 194.21. The WIPP is a disposal system for defense-related 

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 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 

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 remote-handled TRU wastes within the repository, the

emplacement of magnesium oxide (MgO) backfill in appropriate amounts to fulfill DOE commitments and 

requirements, maintenance of relevant waste packaging records, including the electronic WIPP Waste 

Information System (WWIS). EPA looked at selected activities, such as RH and CH waste processing, waste 

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 properly, and that MgO is emplaced properly. While DOE does 

not necessarily maintain an MgO safety factor above 1.67 for operational efficiency while loading waste 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 during this inspection. However, EPA does repeat the 

recommendation made in 2007: that DOE retain a photographic record to verify the RH canister 

identification number of the remote-handled canister as it is transferred from the transportation cask to the 

facility cask and include the photographic record with the permanent record package. 

 

1WIPP Land Withdrawal Act, Public Law 102-579, Section 2(18), as amended by the 1996 WIPP LWA Amendments, 

Public Law 104-201. 
5

2.0 INSPECTION PURPOSE AND SCOPE

 The purpose of this annual inspection was to determine if contact-handled (CH) and remote-handled 

(RH) transuranic (TRU) waste sent to WIPP during the past year has been emplaced in the underground 

facility in the manner specified in DOE=s Compliance Certification Application and other approvals. 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 compliance with EPA=s WIPP Compliance Criteria and the 

certification decision of May 18, 1998. Emplacement 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 inspection was to verify that RH waste is emplaced in accordance 

with the plan and procedures specified in the Compliance Certification Application (CCA) and demonstrated 

during the WIPP RH startup inspection of January 9 – 11, 2007. 

 Activities within the scope of this inspection included: 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 relevant 

waste packaging records, including the electronic WIPP Waste Information System (WWIS) and the 

verification of appropriately implemented quality assurance practices. The review and examination of the 

documents related to these processes was an important part of the inspection. 

 

 The WIPP site is operated by Washington TRU-Solutions (WTS) under contract to DOE. The 

majority of waste related activities onsite are described by or controlled through WTS procedures. A list of 

WTS procedures examined for this inspection is provided 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 Department and Jerry Fox and Chris Timm of Pecos 

Management Services also observed the inspection activities. A partial list of inspection participants 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 Carlsbad, 

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 information 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 personnel into the underground repository on the 

morning of July 23, in order to examine waste packages and MgO that had been emplaced in Panel 4. 

Inspectors selected several containers and recorded their numbers (see Figure 5 for container locations); 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 borehole spacing was checked to confirm appropriate 

spacing of RH waste emplacement in the pillars. (Figure 1). 

 

 The inspectors examined waste emplacement operations in the underground and waste that had been 

recently placed in the repository. The inspectors also reviewed records documenting that waste emplacement 

and MgO tracking were conducted in accordance with procedures. To date, the waste received at the 

repository are contact-handled (CH) transuranic wastes from Argonne National Laboratory-East (ANL-E) in 

Illinois, Los Alamos National Laboratory (LANL) in New Mexico, Idaho National Laboratory (INL), 

Hanford Site in Washington, Rocky Flats Environmental Technology Site (RFETS) in Colorado, Savannah 

River Site (SRS) in South Carolina, and the Nevada Test Site (NTS) in Nevada. These wastes are in several 

configurations: Standard Waste Boxes (SWBs), 55-gallon drums assembled in groups of seven called a 

Seven Pack, 100 gallon drums for supercompacted waste, 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 Summary 

Reports, Waste Emplacement Reports and Waste Container Data Reports for RH and CH waste. 
8

Figure 2 

Figure 2 Illustrates the arrangement of disposed waste 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 panel consisting of seven rooms. At the time of the 

inspection, CH waste was being emplaced in Room 3 of Panel 4. Waste containers are stacked in columns 

(waste stacks) combining SWBs, drum packs, and TDOPs (see Figure 3, 4, and 5). TDOPs are always 

placed on the floor of the room, occupying the bottom 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 are in 

a series of staggered rows, with a row consisting of three columns that span the distance of a disposal room 

from left to right (Figure 2 and 3). Remote-handled waste is placed in the walls on eight foot centers 

(Figures 1, 3, 6, and 7). 
9

Figure 3 

Typical RH and CH TRU Mixed Waste Disposal Configuration 
10

While underground in Room 3, Panel 4, EPA inspectors selected recently emplaced waste packages 

for review. The inspector read the shipment identification numbers directly off the emplaced containers (See 

Figure 5 for CH locations). The containers selected 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 Container Data Report 

• Certification Module, linked to the Acceptance/Rejection Report 

• Shipping Module, linked to the Shipment Summary Report 

• Inventory Module, linked to the Nuclide Report, Waste Emplacement Report and the MgO safety factor 

calculation on the Emplace Containers Underground (Attachments G). 

 All records were found to contain the required information. EPA recommends that a permanent 

photographic record of the RH canister number be placed in the RH record package to enhance traceability 

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 chemistry of the room. EPA approved lowering the required 

safety factor to 1.2 from 1.67 in a letter dated February 11, 2008. At the time of the inspection, DOE was 

using the old safety factor of 1.67 or greater, which means that MgO in amounts of at least 1.67 times the 
11

amount of carbon will always be in the repository to control chemical conditions and remove carbon dioxide 

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 guiding 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 properly emplaced. In addition to the requirement in WTS 

Technical Procedure WP 05-WH1011, DOE addresses the addition of MgO in the WIPP Waste 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, standard 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 January 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 WWIS documentation to confirm appropriate transfer 

and emplacement. 

 EPA reviewed various aspects of RH waste “operational MODES” (“MODES are established to 

provide a safe, structural approach to facility operation”, DOE /WIPP-06-3178, page 1-7). These include RH 

Waste handling, RH Waste Storage and RH Standby Modes. 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 and 

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 components 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 106 kg. The minimum limit is 2 x 107 kg iron. With total metals 

at 5.7 x 106 kg, the WIPP is approaching 29% of the minimum amount 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 for CPR 

was 2.2 x 107 kg and this is the limit EPA has required DOE to meet. However, in the subsequent 

performance assessment baseline calculations, DOE added packaging materials to the calculations, and now 

the CPR limit for WIPP is 2.4 x 107 kg (see Table C). CPR values are tracked on a per container basis and 

the current CPR values as of July 21, 2008 are listed in Table C. 

 As of this inspection the WIPP contained almost 3.7 x 106 kg of CPR in waste and 1.3 x 106 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 106 kg of CPR. This is a total of nearly 5.3 x 106 kg 

of cellulosic, plastic and rubber material. Most of this is split between the cellulosic and plastic materials; the 

mass of rubber materials now account for about 5% of the total mass of CPR, compared to 4.7% in 2007 and 

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 activities 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 safety factor was above the mandated 1.67 for closed rooms 

since the tracking officially began with Room 1, Panel 2 and Room 7, Panel 3 at the time of the inspection 

(see Attachment E). 

 

 The surface processing of RH and the underground operation of RH container emplacement were 

reviewed and found to be adequate according to specified plans documented in the CCA. EPA did not 

identify any findings or concerns during this inspection. 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 Application 

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 authority of 40 CFR 194.21, which authorizes the 

Agency to inspect the WIPP during its operational period to verify continued compliance with EPA’s WIPP 

Compliance Criteria and the certification decision of May 18, 1998. 

Scope: 

 The scope of this inspection includes: demonstration of the site’s ability to receive, process, and 

emplace contact-handled and remote-handled TRU wastes within the repository, the use of magnesium oxide 

(MgO) backfill in appropriate amounts to fulfill DOE commitments and requirements, maintenance of 

relevant waste packaging records, including the electronic WIPP Waste Information system (WWIS) and the 

verification of appropriately implemented quality assurance practices. The availability of documentation of 

these processes and activities will be a major source of review. 

Focal Areas for this Year’s Inspection: 

- What changes have taken place to emplacement activities and documentation since last year’s 

inspection. 

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

Location: 

 The inspection will be held at the DOE’s WIPP facility 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 of records related to waste emplacement, and other 

information as needed. 

Duration: 

 The EPA expects to complete its inspection in about 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 session. 

Expected Date: Week of July 21, 2008 

Documents For Review: 

 Electronically provide for this inspection the latest 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 85868 

 
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 drums of site generated waste, two drums from RFETS that were overpacked 

on site, with primarily empty dunnage drums but with some salt-filled dunnage drums. 

Argonne National Laboratory - East (ANL-E) Hanford Site (Hanford) 

Idaho National Engineering and Environmental Laboratory (INEEL) Los Alamos National Laboratory (LANL)

Lawrence Livermore National Laboratory (LLNL) Rocky Flats Environmental Technology Site 

(RFETS) 

Nevada Test Site (NTS) Savannah River Site (SRS) 

Waste Isolation Pilot Plant (WIPP) 

Drums = 55 gallon (208 liter or 0.208 m3) steel drums Pipe Overpack = 55 gallon drum pipe 

overpack except for the S100 

SWB = Standard Waste Box TDOP = ten drum overpack 

Dunnage = inert drums used to complete waste assemblies 
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 Weight (kg) 

1 Waste Iron base Metal Alloys 5,403,886.18 

2 Waste Aluminum Based Metal /Alloys 38,821.48 

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 5,857,381.26 

10 Waste Solidified Organic Material 393,205.16 

12 Waste Soils 19,270.68 

13 Steel - 

Packaging Steel Container Materials 10,420,254.93 

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 Safety 

Panel Room (kg) (kg) (kg) Factor 

----- ----- ---------- ---------- ---------- ------- 

1 7 1,127,526 508,254 276,990 2.01 

 6 222,885 101,210 86,116 1.44 

 5 222,885 160,047 79,213 1.56 

 4 228,600 128,597 85,525 1.51 

 3 1,034,415 749,764 342,069 1.67 

 2 1,028,825 948,002 229,442 2.17 

 1 617,220 311,843 138,330 2.14 

2 7 1,028,700 571,001 236,830 2.09 

 6 982,980 461,528 209,305 2.20 

 5 988,820 498,970 197,609 2.29 

 4 977,265 518,555 220,912 2.17 

 3 1,028,700 667,662 211,841 2.27 

 2 965,835 733,025 165,412 2.62 

 1 691,515 416,679 186,200 1.71 

3 7 960,120 711,188 104,831 4.03 

 6 954,405 876,558 228,033 1.95 

 5 1,022,985 808,693 284,651 1.70 

 4 960,120 899,470 255,054 1.79 

 3 931,545 1,000,561 243,860 1.89 

 2 944,880 1,004,479 227,889 2.03 

 1 662,940 722,043 183,072 1.76 

4 7 942,975 1,051,062 248,903 1.90 

 6 925,830 945,599 267,494 1.71 

 5 946,785 890,039 265,295 1.71 

 4 1,013,460 830,990 290,608 1.70 

 3 363,855 334,452 150,581 1.16 

 2 0 4,642 1,523 .00 

==================================================== 
22

Attachment F

Room 3, Panel 4 MgO Safety Factor Calculation for August 25, 2008 
23

Attachment G

Procedures Examined

> NS-E2008-1: CH Waste Processing, Technical Procedure WP 05-WH1011, Revision 26; Effective 

Date: March 28, 2007 

> NS-E2008-2: Waste Stream Profile Form Review and Approval Program, 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 Version 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 Analysis DOE/WIPP-95-2065, 

Revision 10, November 2006 

> NS-A2008-H: WIPP RH Waste Documented Safety Analysis DOE/WIPP-06-3174, Revision 0, March 

2006 

> NS-E2008-5: WIPP RH Technical Safety Requirement DOE/WIPP-06-3178, Revision 0, March 2006 

> NS-E2008-6: Specification for Prepackaged MgO Backfill, Specification, D-0101, Revision 7, 

Revision Date: May 12, 2005 

> NS-E2008-7 : Conduct of Operations WP 04-CO, Revision 8, Effective Date: March 11, 2008 

> NS-E2008-8 : Horizontal Emplacement and Retrieval Equipment Assembly, Technical Procedure, 

WP05-WH1700, Revision 6, Effective Date: April 30, 2008 

> NS-E2008-9 : Road Cask Transfer Car Operation, Technical Procedure, WP 05-WH1701, Revision 9, 

Effective Date: October 31, 2006 

> NS-E2008-10 : Facility Cask Transfer Car 41-H-003 Operation, Technical Procedure, WP 05-

WH1704, Revision 6, Effective Date: January 19. 2006 

> 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, Technical Procedure, WP 05-

WH1713, Revision 7, Effective Date: August 29, 2007

> NS-E2008-16: RH Cask Preparation Station 41-Z-076, Technical Procedure, WP 05–WH1714, 

Revision 1, Effective Date: June 21, 2006 

> NS-E2008-17: Cask Unloading Room Shield Door Operation, Technical 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 Inspections, Technical 

Procedure, WP 05-WH1744, Revision 8, Effective Date: February 28, 2007 

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

WH1752, Revision 3, Effective Date: July 10. 2006 

> NS-E2008-23: RH Waste Handling Abnormal Operations, Technical Procedure, WP 05-WH1758, 

Revision 4, Effective Date: May 17, 2007 

> NS-E2008-24: Categorization and Classification of Operational Emergencies 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: December 17, 

2003 

> NS-E2008-25: Hazardous Material Spill and Release Response, Emergency 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/ ReCertification 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 Panel 

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 discussed 

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. Procedure 

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 Uniform 

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 inspectors 

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 these 

records exist for these containers and determined that 

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 these 

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 verification. 

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 below 

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 for 

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 information 

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 module 

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 shipment 

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 that 

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 factor of 

1.67 must be maintained. In a letter dated February 

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 the 

WWIS. The MgO safety factor calculation is done 

routinely as described in WP 05-WH.01, Attachment 

1. The inspector verified this activity. 

Satisfactory