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) conducted an annual inspection of the 

Department of Energy (DOE) Waste Isolation Pilot Plant (WIPP) June 20 to June 22, 2006 as 

part of our continuing oversight program. This inspection was conducted under the authority of 

40 CFR 191, Subpart A. The purpose of this inspection was to verify that DOE 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 releases to the public due to normal 

waste disposal operations and any unplanned or accidental releases that might occur during 

disposal operations. EPA reviewed DOE’s activities related to underground continuous air 

monitors (CAM) false alarms examined during the last 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 DOE’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 monitoring program during the past 

year, responded aggressively and appropriately to the CAM alarms and Station A issues. 

Moisture and salt loading continues to challenge the 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 an effective radiation sampling program 

because of the diligence of site staff, and can calculate 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 WIPP continues to effectively capture, 

measure, and calculate radiation doses to members of the public during waste disposal 

operations. Inspection activities included an examination of monitoring and sampling equipment 

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 specific review the impact of moisture 

and salt loading on the sampling location at Station 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 Kline, 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 Harward and WIPP laboratory activities by 

Monsour Akbarzadeh. DOE discussed changes in the program 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 ventilation system, 

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

- Procedures for both effluent monitoring and laboratory analysis have had minor changes, and 

- Changes related to the underground CAMs. 
3

 The EPA inspector observed various activities to verify effective implementation of 

DOE/WTS procedures. EPA reviewed procedures and implementation; interviewed site staff 

about the steps involved in the changes in underground CAMs, such as new sample heads, to 

mitigate High-High fault events, observed filter changes at Stations A, B, and C, and 

underground CAM sampling locations at the air exhaust of the waste emplacement room in Panel 

three. This year EPA staff discussed, in detail, the persistent problems with moisture and the 

resultant salt loading on the Station A shrouded probes. 

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 appeared 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 last year. DOE/WTS instituted three 

changes: 1) daily cleaning of the detectors with compresses air, installation of a new Canberra 

Model CAM490 AB detector head, and reduction of underground ventilation in the waste panel 

area during backshifts (non-waste emplacement periods) to reduce condensation on the detector 

head. Salt dust is blown off of the sample head daily 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 persistent 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 representative samples at this location. Even 

though studies have been done in the past that showed that the shrouded probe is ideal for 

application at Station A and out performs other sampling 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 13th 2006
4

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

 In Effects of Salt Loading and Flow 

Blockage on the WIPP Shrouded Probe by 

Chandra, Ortiz, and McFarland (COBA2006-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 operating effectively. DOE has committed to 

reevaluate their criteria to more effectively determine the impact of salt loading on Station A 

probe performance. 

DOE/WTS and EPA had extensive discussions during inspection interviews to attempt to 

determine the overall effectiveness of effluent sampling at Station A. Ultimately, EPA 

determined that it was not totally clear that Station 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 following commitments from DOE during the 

inspection, summarized in an email dated June 22, 2006 (COB-A2006-5). DOE committed to: 

- ensure that sampling at Station A will be representative of the air flow from the underground 

 by increasing the frequency of preventative maintenance. 

- re-evaluation of the shrouded probe acceptance criteria. 

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

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

 consideration of alternatives to Station A. 

 Fundamentally, DOE will start and continue bi-weekly, or more frequently as needed, 

Station A probe pulls and cleaning until the salt loading is decreased to acceptable levels or an 

adequate alternative is approved to replace or appropriately supplement Station A as the primary 

compliance point for Subpart A requirements. DOE will also evaluate and modify, as 

appropriate, the screening criteria used to determine 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 continued 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 probe changes and cleanings, working 

to improve probe acceptance criteria, and efforts to find possible alternatives to Station A are 

reasonable and adequate and will ensure that Station 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 performed during FY 06. He also noted minor 

changes to laboratory procedures. EPA inspectors also 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 radiological monitoring and sampling 

program for WIPP disposal operations and appropriately performs calculations to estimate 

potential releases to the public. EPA had no findings 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 reporting 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 limits expressed in Section 191.03. This 

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

Scope: 

Inspection activities will include an examination of the description of monitoring and sampling 

equipment both on and off site, and in the underground. 

A particular focus of this inspection will be the continued challenges of moisture and salt builtup on the shrouded probes at Station A and its potential impact on the quality and adequacy of 

samples collected at Station A. 

EPA inspectors also wish to begin an in-depth evaluation of the Subpart A sampling 

requirements for the handling and disposal of RH waste at the WIPP site. Prior to EPA approval, 

EPA must verify that the DOE can monitor and calculate possible radiation doses to members of 

the public due to normal operations and any accidental RH releases which could occur. 

Location: 

This inspection will be held at the WIPP facility located twenty-six miles south east of Carlsbad, 

New Mexico and the surrounding vicinity as needed. 

Duration: 

EPA expects to complete its inspection in three days. Each day will begin with an opening 

meeting at 8:00 a.m. and end at 5:00 p.m. with a closeout session. 

Expected Dates: Week of June 19, 2006. 

Documents Required for Review: 

DOE must provide the most recent annual Safety Analysis Report, information that describes 

how measurements are taken, and complete documentation that shows how compliance 

calculations are performed with an explanation of all input parameters and their derivation and 

all related to Subpart A requirements (such as current 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 required, 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 (DOEWIPP 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:COBA2006-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 (COBA2006-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:COBA2006-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:COBA2006-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:COBA2006-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:COBA2006-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 (COBA2006-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 9x105

cm3/hr. 

Assume ingestion rate of meat to be 85 

kg/yr. 

Assume ingestion rate of leafy vegetables 

to be 18 kg/yr. 

Assume ingestion of milk to be 112 

liter/yr. 

Assume ingestion rate of produce to be 176 

kg/yr. 

EPA 402-R-97-001 

Section 2.7.3, Page 

10 

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:COBA2006-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-R97-001 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/WIPP95-2065: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