### DOCKET NO: A-98-49

Item: II-B3-97



## 2006 - Subpart A Inspection Report

INSPECTION No. EPA-WIPP-6.06-20a

OF THE

WASTE ISOLATION PILOT PLANT June 20 to June 22, 2006

U. S. ENVIRONMENTAL PROTECTION AGENCY

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

September 2006

### Table of Contents

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

**................................................... ................................. 1** 

**2.0 Scope..........................................**

**................................................... ............................................ 1** 

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

**................................................... .................... 1** 

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

**................................................... ............................. 2** 

**5.0 Summary of Findings............................**

**................................................... ................................. 5** 

**Attachments**

**Attachment A Inspection Plan and Checklist**

**Attachment B Documents Reviewed**

### 1

1.0 Executive Summary

**The U.S. Environmental Protection Agency (EPA) con ducted an annual inspection of the**  **Department of Energy (DOE) Waste Isolation Pilot Pl ant (WIPP) June 20 to June 22, 2006 as**  **part of our continuing oversight program. This ins pection was conducted under the authority of**  **40 CFR 191, Subpart A. The purpose of this inspect ion was to verify that DOE was in continued**  **compliance with the dose release standard found at 40 CFR 191.03, Subpart A.** 

**EPA reviewed DOE’s ability to monitor radiation re leases to the public due to normal**  **waste disposal operations and any unplanned or acci dental releases that might occur during**  **disposal operations. EPA reviewed DOE’s activities related to underground continuous air**  **monitors (CAM) false alarms examined during the las t inspection. This year EPA examined**  **DOE’s continued moisture problems and salt loading at the Station A sampling location in the air**  **exhaust shaft, in particular inspectors evaluated D OE’s ability to continuously acquire**  **representative particulate samples. EPA inspectors examined WIPP’s emission control 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 found that DOE continued to improve its air mo nitoring program during the past**  **year, responded aggressively and appropriately to t he CAM alarms and Station A issues.**  **Moisture and salt loading continues to challenge th e Station A sampling location. During this**  **inspection DOE committed to increase probe cleaning frequency and to work toward a solution**  **to this continued problem. DOE continues to have a n effective radiation sampling program**  **because of the diligence of site staff, and can cal culate both yearly and accidental dose estimates**  **adequately. EPA had no findings or concerns during this inspection.** 

2.0 Inspection Scope

**The scope of this inspection was to verify that WI PP continues to effectively capture,**  **measure, and calculate radiation doses to members o f the public during waste disposal**  **operations. Inspection activities included an exam ination of monitoring and sampling equipment**  **both on and off site, and in the underground. This inspection was conducted under the authority**  **of 40 CFR 191, Subpart A.**

**During this inspection, the Agency selected for sp ecific review the impact of moisture**  **and salt loading on the sampling location at Statio n A.** 

3.0 Inspection Team, Observers, and Participants

**The inspection team consisted of four EPA staff. Four members of the New Mexico**  **oversight group also observed the inspection, Tom K line, Robert Blohm, John Hascherts, and** 

**Dean Foster.**

### 2

Inspection Team Member Position Affiliation

**Chuck Byrum Inspection Leader EPA**

**Barnes Johnson Observer EPA**

**Nick Stone Observer EPA**

**Tom Peake Observer EPA**

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

Participant or Observer Affiliation

**Steve Casey DOE/CBFO**

**Joel Siegel WRES**

**Don Harward WTS**

**Mansour Akbarzadeh WTS**

**Hardy Bellows WTS**

**Dave Kump WTS**

**Ed Flynn WTS**

**John VandeKraats WTS**

4.0 Performance of the Inspection

**The inspection began on Tuesday, June 20, 2006 with an opening meeting that included**  **presentations on changes in air monitoring by Don H arward and WIPP laboratory activities by**  **Monsour Akbarzadeh. DOE discussed changes in the p rogram since the last EPA inspection in**  **July 2005. This discussion included the following changes to the program at WIPP during the** 
**past year:**

**- Modification of the waste handling building venti lation system,** 

**- Station A changes, increased probe inspection and cleaning frequency,** 

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

**- Changes related to the underground CAMs.**

### 3

**The EPA inspector observed various activities to v erify effective implementation of**  **DOE/WTS procedures. EPA reviewed procedures and im plementation; interviewed site staff**  **about the steps involved in the changes in undergro und CAMs, such as new sample heads, to**  **mitigate High-High fault events, observed filter ch anges at Stations A, B, and C, and**  **underground CAM sampling locations at the air exhau st of the waste emplacement room in Panel**  **three. This year EPA staff discussed, in detail, t he persistent problems with moisture and the**  **resultant salt loading on the Station A shrouded pr obes.** 

4.1 Overall Inspection Activities

**The inspector observed sampling filter changes at Stations A, B, C, examined**  **photographs of the most recent monthly shrouded probe change in June 2006 (Figure 1), and**  **reviewed underground CAM changes since last**

**year.**

4.2 CAM Alarms Focused on Last Year

**During the 2005 inspection EPA closely examined the underground CAM air samplers’**  **persistent High-High alarms (Docket A-98-49, Item II-B3-82). The CAM would periodically**  **produce a false alarm and cause the air handling system to go into HEPA filter mode. After**  **investigation, DOE/WTS determined that the cause ap peared to be a combination of moisture**  **and salt accumulation causing the detector head to malfunction. During the 2006 inspection site**  **DOE/WTS staff, Ed Flynn, described changes since la st year. DOE/WTS instituted three**  **changes: 1) daily cleaning of the detectors with c ompresses air, installation of a new Canberra**  **Model CAM490 AB detector head, and reduction of und erground ventilation in the waste panel**  **area during backshifts (non-waste emplacement perio ds) to reduce condensation on the detector**  **head. Salt dust is blown off of the sample head da ily using an air-compressor and new sample**  **heads have been installed that appear to eliminate the false alarm problem. DOE/WTS has not**  **had a false High-High alarm since July 2005 on the underground CAMs (COB-A2006-S24).**  **EPA believes that DOE/WTS has adequately responded to this problem.** 

4.3 Continue Moisture Problems at Station A

**During the fall and winter of 2005/2006 DOE had per sistent moisture related salt buildup**  **at the station of record for compliance with 40 CFR 191, Subpart A – Station A. This problem**  **may negatively impact DOE’s ability to acquire repr esentative samples at this location. Even**  **though studies have been done in the past that show ed that the shrouded probe is ideal for**  **application at Station A and out performs other sam pling methods, some studies have shown that**  **performance efficiency can be impacted by excessive salt loading (COB-A2006-9, COB-A2006-**  **Figure 1 A**

**- 3 Probe as Found**  **June 13 th**  **2006**

### 4

**ZE, COB-A2006-ZB, and COB-A2006-ZA). EPA focused o n this issue during this inspection.** 

**In** Effects of Salt Loading and Flow Blockage on the WIPP Shrouded Probe **by Chandra, Ortiz, and McFarland (COB**  **A2006-ZB) they show that the most critical performance measure for the shrouded**  **probe is the inlet effective diameter. Decreasing this diameter by salt loading can**  **decrease effluent particulate flow into the sampling system. The waistline space, the**  **space between the shroud and the probe (Figure 1), is of much less importance in**  **determining the shrouded probe performance. DOE has been using the** 

**criteria of one-third occlusion of the waistline space to determine if a probe is operatin**  **g effectively. DOE has committed to reevaluate their criteria to more effectively deter**  **mine the impact of salt loading on Station A probe performance.** 

**DOE/WTS and EPA had extensive discussions during in spection interviews to attempt to** 

**determine the overall effectiveness of effluent sam pling at Station A. Ultimately, EPA**  **determined that it was not totally clear that Stati on A was able to acquire adequate samples**  **during periods of significant salt loading (Figure 1, you can see salt loading in the waistline and**  **on the probe inlet). Therefore, EPA obtained the f ollowing commitments from DOE during the**  **inspection, summarized in an email dated June 22, 2 006 (COB-A2006-5). DOE committed to:** 

**- ensure that sampling at Station A will be represe ntative of the air flow from the underground**  **by increasing the frequency of preventative mainte nance.** 

**- re-evaluation of the shrouded probe acceptance cr iteria.** 

**- development of a nozzle measurement technique to be used for acceptance determinations.** 

**- evaluation of Station D for additional sampling p oints (longer term), as well as further** 

**consideration of alternatives to Station A.**

**Fundamentally, DOE will start and continue bi-week ly, or more frequently as needed,**  **Station A probe pulls and cleaning until the salt l oading is decreased to acceptable levels or an**  **adequate alternative is approved to replace or appr opriately supplement Station A as the primary**  **compliance point for Subpart A requirements. DOE w ill also evaluate and modify, as**  **appropriate, the screening criteria used to determi ne if a Station A probe is operating adequately.**  **Figure 2 Station A Filter Change**

### 5

**Over the past year salt loading at Station A has c ontinued to be a persistent problem,**  **therefore, DOE also agreed to search for effective alternatives to Station A as the compliance**  **point for Subpart A compliance.**

**EPA believes that DOE commitments to increased pro be changes and cleanings, working**  **to improve probe acceptance criteria, and efforts t o find possible alternatives to Station A are**  **reasonable and adequate and will ensure that Statio n A will continue to fulfill the requirements**  **of 40 CFR 191, Subpart A.**

4.4 Other Inspection Activities

**EPA observed filter changes at Stations A (Figure 2), B, and C to verify appropriate**  **implementation of site procedures. Also during the opening meeting Mansour Akbarzahdeh**  **summarized WIPP laboratory sample analysis performe d during FY 06. He also noted minor**  **changes to laboratory procedures. EPA inspectors a lso examined the underground CAM**  **locations and the underground Station D location. EPA found all activities consistent with**  **established procedures.**

5.0 Summary of Findings

**EPA concludes that DOE adequately implements a rad iological monitoring and sampling**  **program for WIPP disposal operations and appropriat ely performs calculations to estimate**  **potential releases to the public. EPA had no findi ngs or concerns.** 

### 6 Attachment A : Inspection Plan and Checklist 2006 Subpart A Inspection Plan

Purpose **: EPA will verify that the Department of Energy (DOE)**  **has been monitoring and calculating possible radiation doses to members of the public,**  **due to normal operations and any accidental releases, which may have occurred during the last r**  **eporting period. This inspection is part of EPA’s continued oversight to ensure that WIPP can,**  **during the operational phase of management and storage of radioactive waste, comply with the l**  **imits expressed in Section 191.03. This inspection is conducted under the authority of 40 C**  **FR 191, Subpart A.**

Scope **: Inspection activities will include an examination o**  **f the description of monitoring and sampling equipment both on and off site, and in the undergro**  **und.**

**A particular focus of this inspection will be the c ontinued challenges of moisture and salt built**  **up on the shrouded probes at Station A and its pote ntial impact on the quality and adequacy of**  **samples collected at Station A.**

**EPA inspectors also wish to begin an in-depth evalu ation of the Subpart A sampling**  **requirements for the handling and disposal of RH wa ste at the WIPP site. Prior to EPA approval,**  **EPA must verify that the DOE can monitor and calcul ate possible radiation doses to members of**  **the public due to normal operations and any acciden tal RH releases which could occur.** 

Location **: This inspection will be held at the WIPP facility l**  **ocated twenty-six miles south east of Carlsbad, New Mexico and the surrounding vicinity as needed.** 

Duration **: EPA expects to complete its inspection in three day**  **s. Each day will begin with an opening meeting at 8:00 a.m. and end at 5:00 p.m. with a cl**  **oseout session.**

Expected Dates **: Week of June 19, 2006.**

Documents Required for Review: **DOE must provide the most recent annual Safety Anal ysis Report, information that describes**  **how measurements are taken, and complete documentat ion that shows how compliance**  **calculations are performed with an explanation of a ll input parameters and their derivation and**  **all related to Subpart A requirements (such as curr ent versions of Letter Report by CTAC,**  **Subject: WIPP Air Monitoring Status Second Quarter 2006, 07/11/05, by Susan McCauslin; and,**  **Radiological Material Control, Technical Procedure, WP 12-HP3200, Revision 8, 04/28/05). If**  **there are any questions as to the documents require d, please contact Chuck Byrum at 214-665-** 

**7555.**

### 7

**#** CHECKLIST QUESTION June 2006 40 CFR 191.03 Subpart A

40 CFR 191.03 Compliance Standard EPA Citation Comment (Objective Evidence) Result

**Does DOE “...provide reasonable assurance that the combined annual dose equivalent to any**  **member of the public in the general environment resulting from: (1) Discharges of** 

**radioactive material and direct radiation from such management and storage and (2) all**  **operations covered by Part 190; shall not exceed 25 millirems to the whole body, 75**  **millirems to the thyroid, and 25 millirems to any other critical organ.” 40 CFR 191.03(a)**  **40 CFR 191.03 Subpart A -** 

**Environmental**

**Standards for Management and**  **Storage DOE has demonstrated that they can** 

**capture, measure, and calculate releases to assure that they are and** 

**remain below these limits**

**. Sat.** 

Scope of activities considered in determining compliance

**1 Does DOE demonstrate that all activities at**  **the WIPP up until the point of disposal are considered in determining compliance?**  **EPA 402-R-97-**

**001 Section 2.3, Page** 

**4 The Site Environmental Report (DOE** 

**WIPP 05-2225:COB-A2006-C) Executive Summary documents the** 

**results of DOE’s efforts to consider all activities that impact compliance.**  **Sat.**

**2 Does DOE demonstrate that radiation**  **doses to the public due to 1) actual normal operation and**  **2) any unplanned or accidental**

**releases are examined? EPA 402-R-97-** 

**001 Section 2.3, Page** 

**5 Section 3.0 of DOE/WIPP 00-3121:** 

**COB-A2006-A, documents the plan to show how this requirement is examined.**  **WP 12-RC.01:COB-A2006-F, documents the QA requirements for the**  **sampling of emissions. Annual NESHAP report (COB-A2006-I)**  **demonstrate that normal operations are**

**examined. DOE/WIPP 95-2065:COB**

**A2006-G documents DOE’s review of potential accidents at WIPP. Procedure** 

**WP 12-HP4000:COB-A2006-J documents radiological emergency** 

**response. Sat.** 

Media considered in determining compliance

**3 Does DOE demonstrate that the air**  **pathway is the credible release pathway? EPA 402-R-97-** 

**001 Section 2.4, Page** 

**5 DOE/WIPP 05-2225:COB-A2006-C** 

**page(s) vii, 2-2 documents that the air pathway is the only credible release**  **pathway. Sat.** 

**4 Does DOE demonstrate that other exposure** 

**mechanisms from an air release could include inhalation of contaminated air, immersion in a**  **plume of radioactive particles, ingestion of soil 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 DOE/WIPP 00-** 

**3121:COB-A2006-A documents the detailed plan for measuring these**  **potential exposure mechanisms. Annual NESHAP report (COB-A2006-I)**  **demonstrates that these exposure**

**mechanisms are included. Sat.** 

SAT = Satisfactory USAT = Unsatisfactory

### 8

**#** CHECKLIST QUESTION June 2006 40 CFR 191.03 Subpart A

Media considered in determining compliance EPA Citation Comments (Objective Evidence) Result

**5 Is DOE monitoring the expected air exhaust pathway and performing**  **environmental monitoring of other release points and exposure pathways to confirm**  **air exhaust as the only release pathway? EPA 402-R-97-001**  **Section 2.4, Page 5 and page 6.**  **Section 2.1 of DOE/WIPP 00-**

**3121:COB-A2006-A explains DOE’s plan to fulfill this**  **requirement. DOE/WIPP 05-**

**2225:COB-A2006-C demonstrates that DOE implements groundwater**  **surveillance, biota sampling and off-site air monitoring programs.**  **Sat.**

Boundary of compliance

**6 Does DOE demonstrate compliance at the “exclusive use area” boundary?**  **If not, does DOE justify changing this boundary?**  **EPA 402-R-97-001 Section 2.5, Page 6.** 

**EPA 402-R-97-001 Section 2.5, Page 7**  **Section 3.1 of DOE/WIPP 00-**

**3121:COB-A2006-A states that the**

**“Exclusive Use Area” will be used as the boundary for 40 CFR 191**  **Subpart A compliance. Sat.** 

Location of maximally exposed individual

**7 Does DOE examine radiation doses to individuals at any offsite point where there**  **is a residence, school, business, or office? (Such as grazing, mining, or oil drilling in**  **the vicinity.) EPA 402-R-97-001**  **Section 2.6.1, Page**

**8 DOE/WIPP 05-2225:COB-A2006-** 

**C Section 1.3.2 and the Annual NESHAP report (COB-A2006-I)** 

**demonstrate that DOE considers doses at appropriate offsite points,** 

**such as Smith Ranch located 7.5 km away in the WNW sector of** 

**WIPP. Sat.** 

**8 Does DOE analyze potential exposure pathways and examine demographic** 

**information and conduct field investigations to identify the location of**  **actual individual who could be exposed via those pathways?**  **EPA 402-R-97-001 Section 2.6.1, Page** 

**8 DOE/WIPP 05-2225:COB-A2006-** 

**C Section 1.3.2 and the Annual NESHAP report (COB-A2006-I)** 

**demonstrate that DOE considers doses at appropriate offsite points,** 

**such as Smith Ranch located 7.5 km away in the WNW sector of** 

**WIPP. Sat.** 

**9 Does DOE conduct separate analyses of potential dose received from each exposure**  **pathway?**

**Then does DOE assume that a member of the public resides at the single geographic**  **point on the surface where the maximum**

**dose would be received? EPA 402-R-97-001**  **Section 2.6.1, Page**

**8 DOE/WIPP 05-2225:COB-A2006-** 

**C Section 1.3.2 and the Annual NESHAP report (COB-A2006-I)** 

**demonstrate that DOE considers doses at appropriate offsite points,** 

**such as Smith Ranch located 7.5 km away in the WNW sector of** 

**WIPP**

. **Sat.**

SAT = Satisfactory USAT = Unsatisfactory

### 9

**#** CHECKLIST QUESTION June 2006 40 CFR 191.03 Subpart A

Personal parameters EPA Citation Comments (Objective Evidence) Result

**10 Does DOE assume that the individual exhibits personal characteristics of the**  **“reference man” when evaluating radiation dose to the maximally exposed** 

**individual? EPA 402-R-97-001**  **Section 2.6.2, Page**

**8 Section 3.2 of DOE/WIPP 00-** 

**3121:COB-A2006-A describes the “reference man” parameters as**  **described in the CAP88-PC computer code. Annual NESHAP report**  **(COB-A2006-I) demonstrates that**

**“reference man” is used to evaluate**

**radiation dose. Sat.** 

Calculation of dose - Modeling -

Parameters

**11 Does DOE provide both whole body**  **radiation dose and critical organ radiation dose for the maximally exposed individual**  **(or a hypothetical individual conservatively located at a point of higher exposure)?**  **EPA 402-R-97-001 Section 2.7.1, Page** 

**8 Annual NESHAP report (COB** 

**A2006-I) demonstrates that DOE appropriately fulfills this**  **requirement. Sat.** 

**12 Does DOE calculate radiation doses including all release points and reflecting**  **evaluation of all exposure pathways? EPA 402-R-97-001**  **Section 2.7.1, Page**

**8 Section 2.1 of DOE/WIPP 00-3121:COB** 

**A2006-A states that the air pathway is the most credible but other exposure**  **pathways are monitored. Annual NESHAP report (COB-A2006-I)**  **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:COB** 

**A2006-A states that a computer model**

**will be used to calculate radiation doses. Annual NESHAP report (COB-A2006-I)**  **demonstrates that DOE is using computer modeling.**  **Sat**

**14 Does DOE use CAP88-PC to perform**

**dose calculations? EPA 402-R-97-001**  **Section 2.7.2, Page**

**9 Section 3.2 of DOE/WIPP 00-3121:COB** 

**A2006-A states that CAP88-PC is used**

**for dose calculations. Annual NESHAP report (COB-A2006-I) demonstrates that**  **DOE is using CAP88-PC. Sat.** 

**15 Does DOE use an alternate model for calculating radiation doses? If so, does**  **DOE justify such usage? EPA 402-R-97-001**  **Section 2.7.2, Page**

**10 Section 3.2 of DOE/WIPP 00-3121:COB** 

**A2006-A states that DOE uses the atmospheric dispersion code (CXQ) to** 

**determine concentrations for accidental**

**releases. Sat.** 

**16 Does DOE adequately supported exposure parameters used in dose** 

**calculations? EPA 402-R-97-001**  **Section 2.7.3, Page**

**10 Annual NESHAP report (COB-A2006-I)** 

**demonstrates that DOE is using appropriate parameters in dose** 

**calculations. Sat.** 

SAT = Satisfactory USAT = Unsatisfactory

### 10

**#** CHECKLIST QUESTION June 2006 40 CFR 191.03 Subpart A

Calculation of dose - Modeling - Parameters EPA Citation Comments (Objective Evidence) Result

**17 Does DOE document that “conservative simplifying assumptions” are used in the** 

**radiation dose calculations? EPA 402-R-97-001**  **Section 2.7.3, Page**

**10 Annual NESHAP report (COB** 

**A2006-I) demonstrates that DOE is using conservative simplifying**  **assumptions in dose calculations. Sat.** 

**18 Are DOE’s exposure parameters as conservative as the following?** 

**For a maximally exposed individual located at a residence, assumed continuous**  **exposure (24 hours per day).**

**For a maximally exposed individual located at a business, office, or school,**  **assume exposure of 8 hours per day.**

**Assume individuals consume 2 liters per day of drinking water from an underground**  **source of drinking water.**

**Assume inhalation rate for air to be 9x10 5** 

**cm 3**  **/hr.**

**Assume ingestion rate of meat to be 85 kg/yr.** 

**Assume ingestion rate of leafy vegetables to be 18 kg/yr.** 

**Assume ingestion of milk to be 112 liter/yr.** 

**Assume ingestion rate of produce to be 176 kg/yr.**  **EPA 402-R-97-001 Section 2.7.3, Page** 

**10 Section 3.2 of DOE/WIPP 00-** 

**3121:COB-A2006-A states that DOE is using these values as**  **exposure parameters. Annual NESHAP report (COB-A2006-I)**  **demonstrates that DOE is using these parameters in dose** 

**calculations. Sat.** 

SAT = Satisfactory USAT = Unsatisfactory

### 11

**#** CHECKLIST QUESTION June 2006 40 CFR 191.03 Subpart A

Emissions and Environmental Monitoring - Air EPA Citation Comments (Objective Evidence) Result

**19 Does DOE demonstrate that effluent flow**  **rate measurements are made using Reference Method 2 of Appendix A to 40**  **CFR Part 60 to determine velocity and volumetric flow rate for stacks and large** 

**vents? EPA 402-R-97-001**  **Section 3.1, Page 11, (1(i))**  **WP 12-RC.01:COB-A2006-F**

**Section 4.1 documents that this requirement is appropriately**  **implemented at WIPP. Sat.** 

**20 Does DOE demonstrate that effluent flow**  **rate measurements are made using Reference Method 2a of Appendix A to 40**  **CFR 60 to measure flow rates through pipes and small vents?**  **EPA 402-R-97-001 Section 3.1, Page**  **11, (1(ii)) Not applicable at WIPP. Duct** 

**diameter associated with WIPP exhaust point exceeds the 40 CFR**  **60 requirements. NA** 

**21 Does DOE demonstrate that the frequency**  **of flow rate measurements depend on the variability of the effluent flow rate?** 

Note: **For variable flow rates, continuous or frequent flow rate measurements are**  **expected to be made. For relatively constant flow rates, only periodic**  **measurements are expected. EPA 402-R-97-001**  **Section 3.1, Page 11, (1(iii))**  **DOE/WIPP 00-3121:COB-A2006-**

**A, Section 3.3.1 states that DOE uses continuous air monitoring at** 

**WIPP and does not need to consider this requirement.**  **NA**

**22 Does DOE demonstrate that radionuclides**  **to be directly monitored or extracted, collected and measured using Reference**  **Method 1 of Appendix A to 40 CFR Part 60 for selected monitoring or sampling** 

**sites? EPA 402-R-97-001**  **Section 3.1, Page 11, (2(i))**  **DOE uses 40 CFR 61 Appendix B**

**Method 114. WP 12-RC.01:COB**

**A2006-F documents in Section 4.1 the location of sampling sites.**  **Sat.**

SAT = Satisfactory USAT = Unsatisfactory

### 12

**#** CHECKLIST QUESTION June 2006 40 CFR 191.03 Subpart A

Emissions and Environmental Monitoring - Air EPA Citation Comments (Objective Evidence) Result

**23**

**a Does DOE demonstrate that radionuclides to be**  **directly monitored or extracted, collected and measured continuously with an in-line detector**  **capable of distinguish relevant radionuclides? As an acceptable alternative to direct radiation**  **monitoring, the effluent air stream may be continuously sampled such that analysis of**  **filters or other collectors will provide an**

**accurate estimate of emissions from a known flow rate during a fixed sampling time.**  **EPA 402-R-97-001 Section 3.1, Page**  **11, (2(ii)) DOE uses periodic monitoring at WIPP** 

**to show compliance with 40 CFR 191 Subpart A. However, DOE/WIPP 00-** 

**3121:COB-A2006-A Section 3.3.1**

**states that DOE uses continuous monitoring. DOE/WIPP 00-** 

**3121:COB-A2006-A Sections 3.5 and**

**3.3.5 document relevant radionuclides at WIPP. Annual NESHAP report**  **(COB-A2006-I) demonstrate that these radionuclides are sampled and tested.**  **NA**

**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....” The WIPP is a batch (continuous) process disposing of** 

**radioactive waste therefore continuous sample is appropriate.**  **EPA 402-R-97-001 Section 3.1, Page**  **11, (2(ii)) DOE/WIPP 99-2194:COB-A2006-** 

**1 Section 5.2.4 and DOE/WIPP 00-**

**3121:COB-A2006-A state that sample sites will acquire**  **representative samples. Recent probe pull photographs at Station**  **A (COB-A2006-6c for an example) appear to show that the probe has**  **salt loading and that the probe, in some cases, does not appear to pass**  **minimum acceptance criteria (COB-A2006-9). During the**  **inspection DOE agreed to enhance probe cleaning and to solve Station**  **A’s problems (COB-A2006-5). 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 approve the method**

**used? EPA 402-R-97-001**  **Section 3.1, Page 12, (2(iii))**  **WP 12-RC.01:COB-A2006-F**

**Section 1.0 documents that DOE used these principles.**  **Sat**

**25 If DOE is using the “Shrouded Probe”,** 

**does DOE demonstrate that this alternative method is being used according to the**  **guidance provide in “An Explanation of Particle Sampling in a Moving Gas Stream**  **Within a Duct Using an Unshrouded and**

**Shrouded Probe”? EPA 402-R-97-001**  **Section 3.1, Page 12, (2(iii)(a))**  **An Assessment of the WIPP Shrouded**

**Probe Against EPA Approval Criteria for Use of Single Point Sampling with** 

**the Shrouded Probe HA:98:0100 (Included in August 2000**  **Inspection Report, A-98-49, II-B3-12, COB**  **191A-AO-2000)(EPA Approval letter COB-A2006-3) documents DOE’s** 

**evaluation of the Shrouded Probe and its compliance with the EPA criteria.** 

**LA-12612-MS:COB-A2006-4 documents how the shrouded probe is** 

**demonstrated for use at WIPP. Sat.** 

SAT = Satisfactory USAT = Unsatisfactory

### 13

**#** CHECKLIST QUESTION June 2006 40 CFR 191.03 Subpart A

Emissions and Environmental Monitoring - Air EPA Citation Comments (Objective Evidence) Result

**26 Does DOE’s quality assurance program meet the performance requirements**  **described in Appendix, Method 114 of 40**

**CFR Part 61? EPA 402-R-97-001** 

**Section 3.1, Page 12, (2(iv))**  **WP 12-RC.01:COB-A2006-F**

**Section 1.0 documents DOE quality assurance requirements.**  **These meet the requirements of 40**

**CFR 61. DOE/WIPP 00-**

**3121:COB-A2003-A Section 4.0 states that DOE implements NQA**  **requirements which are equivalent**

**to Method 114. Sat.** 

**27 If it is impractical to measure the effluent flow**  **rate in accordance with the method(s) in Section 3.1(1) or to monitor or sample extraction**  **according to methods in Section 3.1(2) has**

**DOE demonstrated that the use of alternative**

**effluent flow rate measurement or site selection and sample extraction are appropriate and that**  **the alternate method are used provided the following:** 

**(i) DOE shows that methods in Section 3.1(1) or (2) are impractical;**  **(ii) DOE shows the alternative procedure will not significantly underestimate the emissions;**  **(iii) DOE shows the alternative procedure is fully documented; and**  **(iv) DOE has received prior approval from**

**EPA. EPA 402-R-97-001**  **Section 3.1, Page 12, (3(i) to 3(iv))**  **See question #19, DOE uses**

**Section 3.1 (1)(i) of EPA 402-R 97-001 page 11.**  **NA.**

**28 Does DOE demonstrate that radionuclide**

**emission measurements are in**

**conformance with the methods in Section 3.1(1) and (2) to be made at all release**  **points which have a potential to discharge radionuclides into the air in quantities** 

**which could cause a combined annual dose equivalent in excess of 1% of the dose**  **limit in Subpart A? EPA 402-R-97-001**  **Section 3.1, Page 12 and page 13,**  **(4(i)) Section 3.3.3 of DOE/WIPP 00-** 

**3121:COB-A2006-A documents DOE’s compliance with this**  **requirement. Sat.** 

**29 Does DOE demonstrate that all**

**radionuclides which could contribute greater than 10% of the combined annual**  **dose equivalent for a release point are being measured?**  **EPA 402-R-97-001 Section 3.1, Page**  **13, (4(i)) Section 3.3 of DOE/WIPP 00-** 

**3121:COB-A2006-A documents DOE’s compliance with this**  **requirement. Section 2.0 of**

**DOE/WIPP 97-2238:COB-A2006- B discusses release points**  **measured at to confirm compliance with this requirement.**  **Sat.**

SAT = Satisfactory USAT = Unsatisfactory

### 14

**#** CHECKLIST QUESTION June 2006 40 CFR 191.03 Subpart A

Emissions and Environmental Monitoring - Air EPA Citation Comments (Objective Evidence) Result

**30 If DOE uses alternative procedures to**  **determine emissions, does DOE demonstrate that they have prior EPA**  **approval? EPA 402-R-97-001**  **Section 3.1, Page 13, (4(i))**  **DOE does not use alternative**

**procedures at WIPP. NA** 

**31 Does DOE demonstrate that for other**  **release points which have a potential to**

**release radionuclides into the air it has performed periodic confirmatory**  **measurements to verify the low emissions? EPA 402-R-97-001**  **Section 3.1, Page 13, (4(i))**  **DOE does not have other release**

**points which have a potential to**

**release radionuclides. DOE/WIPP**

**95-2065:COB-A2006-G**

**documents these conclusions. NA** 

**32 Does DOE demonstrate that an evaluation**  **has been done to evaluate the potential for radionuclide emissions for a release point?**  **EPA 402-R-97-001 Section 3.1, Page**  **13, (4(ii)) Section 2.0 of DOE/WIPP-97-** 

**2238:COB-A2006-B documents**

**this evaluation and that WIPP has three release points.**  **NA**

**33 Does DOE demonstrate that estimated** 

**radionuclide release rates are based on discharge of effluent stream that would**  **result if all pollution control equipment did not exist, but the facilities operations were** 

**otherwise normal? EPA 402-R-97-001**  **Section 3.1, Page 13, (4(ii))**  **Section 5.2.4 of DOE/WPP 99-**

**2194:COB-A2006-1 states:**

**“Station A exhausts unfiltered air from the underground repository to**  **the atmosphere. Station B exhausts**

**HEPA filtered air from the underground repository to the**  **atmosphere when in Filtration Mode of operation. Station C** 

**exhausts HEPA filtered air from the Waste Handling Building to the**  **atmosphere.” Stations B and C uses pollution control equipment,** 

**therefore item 33 is not fulfilled. However, because of the nature of**  **these sample locations and that they are filtered continuously this**  **approach is appropriate; therefore the Agency agrees that DOE’s**  **sample methods are adequate. Sat.** 

SAT = Satisfactory USAT = Unsatisfactory

### 15

**#** CHECKLIST QUESTION June 2006 40 CFR 191.03 Subpart A

Environmental Measurements **(Page 1)** EPA Citation Comments (Objective Evidence) Result

**34 Does DOE demonstrate that environmental** 

**measurements of concentrations of radionuclides in air at the critical receptor** 

**locations are used as an alternative to air dispersion calculations in demonstrating**  **compliance with the standard? EPA 402-R-97-001**  **Section 3.1, Page 13, (5)**  **DOE does not use environmental**

**monitoring as an alternative to comply with 40 CFR 191.03**  **Subpart A. DOE samples at release points.**  **NA**

**35 Does DOE demonstrate that air at the point**  **of measurement is continuously sampled**

**for collection of radionuclides if**

**environmental measurements are used? EPA 402-R-97-001**  **Section 3.1, Page 13, (5(i))**  **NA**

**36 Does DOE demonstrate that the**  **environmental measurement program is appropriately designed to collect and**  **measure specifically those radionuclides which are major contributors to the annual**  **radiation dose from the facility? EPA 402-R-97-001**  **Section 3.1, Page 13, (5(ii))**  **NA**

**37 Does DOE demonstrate that radionuclide** 

**concentrations which would cause an annual dose equivalent of 10% of the**  **standard are readily detectable and distinguishable from background?**  **EPA 402-R-97-001 Section 3.1, Page**  **13, (5(iii)) NA** 

**38 Does DOE demonstrate that a quality**  **assurance program that meets the performance requirements described in 40**  **CFR Part 61, Appendix B, Method 114 is**

**conducted for environmental**

**measurements? EPA 402-R-97-001**  **Section 3.1, Page 13, (5(iv))**  **NA**

SAT = Satisfactory USAT = Unsatisfactory

### 16

**#** CHECKLIST QUESTION June 2006 40 CFR 191.03 Subpart A

Environmental Measurements **(Page 2)** EPA Citation Comments (Objective Evidence) Result

**39 Does DOE demonstrate that EPA has granted prior approval for the use of** 

**environmental measurements to demonstrate compliance with the standard?**  **EPA 402-R-97-001 Section 3.1, Page**  **13, (5(v)) DOE has not requested approval to** 

**use environmental measurements. NA** 

Emissions and Environmental Monitoring - Other Media

**40 Does DOE demonstrate that environmental monitoring of other release points or**  **critical receptor locations to confirm air exhaust as the only release pathway?**  **EPA 402-R-97-001 Section 3.2, Page** 

**14. DOE/WIPP 00-3121:COB-A2006-** 

**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-WIPP 05-**

**2225:COB-A2006-C demonstrates that DOE’s environmental program**  **monitors other release points and critical receptor locations.**  **Sat.**

SAT = Satisfactory USAT = Unsatisfactory

### 17

**#** CHECKLIST QUESTION June 2006 40 CFR 191.03 Subpart A

Compliance Reporting EPA Citation Comments (Objective Evidence) Result

**41 Does DOE demonstrate compliance with the Subpart A standard by showing that**  **the annual radiation dose to any member of the public in the general environment**  **falls below the regulatory limits? EPA 402-R-97-001**  **Section 4.2, Page**

**15. Section 5.0 of DOE/WIPP 00-** 

**3121:COB-A2006-A documents that DOE’s plans to report results**  **yearly. COB-A2006-I demonstrates that DOE reports**  **results yearly. Sat.** 

**42 Does DOE report results of monitoring**

**and the dose calculations for each reporting period?**  **EPA 402-R-97-001 Section 4.2, Page** 

**15 Section 5.0 of DOE/WIPP 00-** 

**3121:COB-A2006-A documents that DOE’s plans to report results.** 

**COB-A2006-I demonstrates that DOE reports results of monitoring**  **and dose results yearly. Sat.** 

**43 Does DOE demonstrate that monitoring is performed each calendar year of facility**  **operation, and that radiation doses are calculated after the end of each year?**  **EPA 402-R-97-001 Section 4.2, Page** 

**15 Section 5.0 of DOE/WIPP 00-** 

**3121:COB-A2006-A documents that DOE’s plans to report results yearly.** 

**COB-A2006-I demonstrates that DOE reports results monitoring activities**  **and dose is calculated yearly. Sat.** 

Notification of construction or modification.

**44 Does DOE demonstrate that they have provided the EPA written notification of**  **any planned construction or modification to the WIPP facility, prior to commencing**  **any such activity, if it results in an**

**increase in the rate of emissions of radionuclides during operation?**  **EPA 402-R-97-001 Section 4.3, Page** 

**16. Section 5.0 of DOE/WIPP 00-** 

**3121:COB-A2006-A documents that DOE’s plans to report results**  **yearly. COB-A2006-I demonstrates that DOE reports**  **planned construction and modification during the year.**  **Sat.**

**45 Does DOE demonstrate that advanced** 

**notification was not needed for construction**

**and modification if the radiation dose caused by all the emissions from the new construction**  **or modification is less than 1% of the Subpart**

**A dose limits? EPA 402-R-97-001**  **Section 4.3, Page 16 and page 17.**  **Section 5.0 of DOE/WIPP 00-**

**3121:COB-A2006-A documents that DOE’s plans to report results**  **yearly. Sat.** 

Record Keeping

**46 Does DOE demonstrate documentation is sufficient to allow the Agency to verify** 

**the correctness of the determination made concerning the WIPP’s compliance with**  **Subpart A? EPA 402-R-97-001**  **Section 4.4, Page**

**17. Through its various documents,** 

**Subpart A implementation plan, its annual NESHAP report, and many**  **procedures that support Subpart A activities, DOE demonstrate that** 

**documentation is sufficient to allow EPA to verify compliance with**  **Subpart A. Sat.** 

SAT = Satisfactory USAT = Unsatisfactory

### 18 Attachment B

Table of Documents Reviewed