DOCKET NO: A-98-49 

Item: II-B3-102 

Monitoring Inspection Report

INSPECTION No. EPA-WIPP-7.07-10b 

OF THE 

WASTE ISOLATION PILOT PLANT 

July 10 to July 12, 2007 

U. S. ENVIRONMENTAL PROTECTION AGENCY 

Office of Radiation and Indoor Air 

Center for Federal Regulation 

1200 Pennsylvania Avenue, NW

Washington, DC 20460 

August 2007
 Table of Contents 

1.0 Executive Summary...................................................................................................................1 

2.0 Scope..........................................................................................................................................1 

3.0 Inspection Team, Observers, and Participants...........................................................................2 

4.0 Performance of the Inspection ...................................................................................................2 

 4.1 Monitoring of Geomechanical Parameters .............................................................................3 

 4.2 Monitoring of Hydrological Parameters .................................................................................4 

 4.3 Monitoring of Waste Activity Parameters ..............................................................................5 

 4.4 Monitoring of Drilling Related Parameters ............................................................................5 

 4.5 Monitoring of Subsidence Parameters ....................................................................................6 

5.0 Summary of Findings.................................................................................................................6 

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 inspection of the 

Department of Energy’s (DOE) Waste Isolation Pilot Plant (WIPP) from July 10 to July 12, 

2007, as part of our continuing WIPP oversight program. The purpose of this inspection was to 

verify that DOE continues to adequately monitor ten parameters listed in the Compliance 

Certification Application (CCA), Volume 1, Section 7.0, in particular Table 7-7 (See Table 1, 

COB-M2006-1). Attachment A contains the checklist and the inspection plan used by the EPA 

inspector, and Attachment B lists documents reviewed by the EPA inspector. 

 The inspection examined the implementation of monitoring for geomechanical, 

hydrological, waste activity, drilling related, and subsidence parameters. The EPA inspector 

toured locations where measurements are taken, reviewed parameter databases, and reviewed 

documents and procedures directing these monitoring activities. 

 The inspector found that DOE, through its contractor Washington TRU Solutions (WTS), 

effectively implemented the monitoring programs at WIPP for all areas. EPA did not have any 

findings or concerns. The inspector also confirmed that the results of DOE monitoring programs 

are reported annually. 

2.0 Scope

 The WIPP Compliance Criteria (40 CFR Part 194.42(a)) require DOE to “conduct an 

analysis of the effects of disposal system parameters on the containment of waste in the disposal 

system.” The results of these analyses were included in the 1996 Compliance Certification 

Application (CCA), confirmed in the 2004 Compliance Recertification Application (CRA), and 

were used to develop pre-closure and post-closure monitoring requirements. 

 Volume 1, Section 7.0, of the CCA documented DOE’s analysis of monitoring 

parameters. Table 7-7 of the CCA lists the ten parameters that DOE determined may affect the 

disposal system. These parameters are grouped into major categories and listed in Table 1. 

Table 1 - Monitored Parameters

Geomechanical Parameters- Waste Activity Parameter- 

 -Creep closure, -Waste Activity 

 -Extent of deformation, 

 -Initiation of brittle deformation, and Subsidence Parameter- 

 -Displacement of deformation features. -Subsidence measurements 

Hydrological Parameters- Drilling Related Parameters- 

 -Culebra groundwater composition and -Drilling rate and 

 -Change in Culebra groundwater flow -The probability of encountering a 

 direction. Castile brine reservoir. 
2 

 EPA accepted these ten monitoring parameters in the 1998 Certification Decision and 

confirmed them in the 2006 Recertification Decision. This inspection was performed under 

authority of 40 CFR 194.21, which authorizes EPA to verify the continued effectiveness of the 

parameter monitoring program at WIPP. Inspection activities included an examination of 

monitoring and sampling equipment both on and off site, and in the underground. EPA also 

reviewed numerous sampling procedures and measurement techniques and verified 

implementation of an effective quality assurance program (see the document list in Attachment 

B). 

3.0 Inspection Team, Observers, and Participants

 The inspection team consisted of three EPA staff. Two members of the State of New 

Mexico Environmental Department observed the inspection, Thomas Kesterson and Dean Foster. 

Jerry Fox of Pecos Management Services also observed inspection activities. 

Inspection Team Member Position Affiliation

Chuck Byrum Inspection Leader EPA 

Shankar Ghose Inspector EPA 

Tom Peake Inspector EPA 

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

DOE/Contractor Participants

Rick Salness Ed Flynn 

Joel Siegel Mike Oliver 

Sam Dominguez Stan Patchet 

John VandeKraats Art Chavez 

David Hughes Mansour Akbarzadeh 

Larry Madl Mike Strum 

4.0 Performance of the Inspection 

The inspection began on Tuesday, July 10, 2007, with an opening meeting (COB-A2007-

S2) where changes in the parameter monitoring programs since the previous inspection were 

discussed by site staff (COB-M2007-I4a to –I4g). On July 11, 2007 the inspection continued 

with interviews and demonstrations of various aspects of each parameter monitoring area. On 

July 12, 2007 the EPA inspector examined the database(s) used to store Delaware Basin 

parameters and the WIPP Waste Information System (WWIS) waste computer database system. 
3 

The underground, where geomechanical measurements are taken, was also inspected. The 

inspection closeout meeting was held on July 12, 2007 in Carlsbad New Mexico (COB-A2007-

S2b). 

 The EPA inspector reviewed three fundamental areas to verify continued implementation 

of the DOE parameter monitoring program during the pre-closure phase: 1) written plans and 

procedures, 2) quality assurance procedures and records, and 3) results of the monitoring 

program in the form of raw data, intermediate reports, and final annual reports, if appropriate. 

The inspection checklist in Attachment A provides details of these inspection activities. 

The EPA inspector reviewed various activities to verify effective procedure 

implementation. The inspector observed a demonstration of the WWIS and reviewed the 

Delaware Basin Drilling Surveillance Program, Groundwater Monitoring Program, and the 

Geomechanical Monitoring Program. 

4.1 Monitoring of Geomechanical Parameters

 DOE committed to measure four geomechanical parameters in the CCA: creep closure, 

extent of deformation, initiation of brittle deformation, and displacement of deformation features 

(Table 2). WIPP has four programs that supply information for these four parameters: the 

geomechanical monitoring program, the geosciences program, the ground control program, and 

the rock mechanics program. These programs are documented in the WIPP Geotechnical 

Engineering Program Plan, WP 07-01 (COB-M2007-C). The results of the geotechnical 

program are reported in the Geotechnical Analysis Report for July 2005 - June 2006, 

DOE/WIPP-07-3177, Volumes 1 and 2 (COB-M2007-A and -A2). 

Table 2 - Geomechanical Parameter and Values Measured to Confirm Them 

Monitor Parameters Confirmed by Measuring Related Procedure(s)

creep closure and stresses convergence measurements WP 07-EU1301 

 borehole extensometers WP 07-EU1303 

 WP 07-EU1304 

 WP 07-EU1308 

extent of deformation borehole extensometers WP 07-EU1301 

 borehole observations WP 07-EU1303 

 WP 07-EU1305 

 WP 07-EU1308 

initiation of brittle fracture mapping WP 07-EU1301 

deformation borehole observation WP 07-EU1303 

 WP 07-EU1001 

displacement of deformation geologic mapping comparison WP 07-EU1301 

features WP 07-EU1303 

 WP 07-EU1001 

-From DOE/WIPP 07-3177 (COB-M2007-A), Volume 1, Page 6 
4 

 The EPA focused on geomechancial monitoring parameters during this inspection, in 

particular values that are measured manually – 

such as convergence points, observation 

boreholes, mapping of roof fractures, and 

stratigraphic mapping (see Table 2). These 

manual measurements are used to track and 

confirm long-term performance of these four 

monitor parameters. The inspector, before the 

inspection, selected measurements points (COBM2007-G8) in Room 1 of Panel 4: convergence 

points – roof to floor, E520-S3480-2 A-C and wall 

to wall, E520-S3480 B-D (COB-M2007-G1,-G5); 

observation borehole, OH 530 (COB-M2007-G2,-

G11,-G12,-G13, scratch rod measurement-Figure 

1); roof fracture mapping in Room 1 Panel 4 

(COB-M2007-G7a,-G7b,-G7c); and, mapping of 

stratigraphy in Room 1 Panel 4 (COB-M2007-G9, 

stratigraphy mapping-Figure 2). A remote 

measured extensometer (51X-GE-00376) point 

was also selected for review (COB-M2007-G10). 

 Geomechanical staff manually measured 

these values while the inspector observed 

implementation of procedures and examined the results documented in field data forms or plots. 

After taking the measurements the inspector observed staff inputting these data into the computer 

database (COB-M2007-G14). The inspector 

found that procedures are adequate for proper 

measurements: procedures are implemented 

adequately; documents and field data forms are 

controlled; and, data is adequately checked, 

using check prints when necessary, to assure 

adequate quality. 

 

4.2 Monitoring of Hydrological Parameters

 DOE committed to measure two 

hydrological parameters in the CCA: Culebra 

groundwater composition and changes in the 

Culebra groundwater flow direction. Related parameters are measured and documented in the 

WIPP environmental monitoring program. These programs are documented in the WIPP 

Groundwater Monitoring Program Plan, WP 02-1 (COB-M2007-B). Results of this program are 

documented in the Waste Isolation Pilot Plant Site Environmental Report for 2005, DOE/WIPP 

06-2225 (COB-M2007-I). This document describes the groundwater monitoring program and 

reports results for the previous year. 

Figure 1 Scratch Rod Measurement

Figure 2 Stratigraphy Mapping 
5 

 

 During the 2007 inspection the EPA inspector requested information about changes in the 

program since last year. The opening meeting presentation noted that five new Culebra wells 

were drilled and 4 wells plugged since last year (COB-M2007-I4b). The current well 

monitoring network consists of 45 Culebra, 10 Magenta, 5 dual Culebra/Magenta completions, 1 

Dewey Lake, 2 Bell Canyon, and 17 shallow Santa Rosa/Dewey Lake wells. Besides examining 

the Site Environmental Report for 2005 the inspector examined flow direction maps, well 

location maps, water level measurements, and water chemistry data and plots (COB-M2007-H1, 

-H1a, -H1b, -H2, -H3, -H4, -H5, -H6, -H7a, -H7b, -H8, -H10, -H16, -H19, and -H20) during the 

2007 inspection. The inspector found the hydrological monitoring program to be improving and 

adequate. 

4.3 Monitoring of Waste Activity Parameters

 DOE committed to monitor the activity of waste emplaced in the CCA. This parameter is 

part of the extensive database collected for each container shipped to WIPP and is stored in the 

WIPP Waste Information System (WWIS). The WWIS is a software system that screens waste 

container data and provides reports on the Transuranic (TRU) waste sent to WIPP. The 

requirements for the WWIS are discussed in the WIPP Waste Information System Program and 

System Data Management Plan, WP 08-NT.01 (COB-M2007-E). DOE yearly reports waste 

activity information in the Annual Change Report Table 3 (DOE/WIPP 06-3177; COB-M2007-

K). 

 WWIS staff demonstrated that the WWIS can receive data and that the WWIS can 

generate needed reports. The inspector obtained copies of the Nuclide Report (COB-M2007-

W1), WWIS Shipment Summary Reports (COB-M2007-W2 and -W3) and WWIS Waste 

Container Data Reports (COB-M2007-W4, -W5, -W6, and -W7). The inspector verified that 

DOE tracks and annually reports the waste activity at WIPP. 

4.4 Monitoring of Drilling Related Parameters

 DOE committed to measure two drilling related parameters in the CCA: the drilling rate 

and the probability of encountering a Castile brine reservoir. These parameters are measured as 

part of the Delaware Basin Drilling Surveillance Plan, WP 02-PC.02 (COB-M2006-F). This 

surveillance program measures and records many parameters related to drilling activities around 

the WIPP site. The results of the surveillance program are documented annually in the Delaware 

Basin Monitoring Annual Report, DOE/WIPP 06-2308 (COB-M2007-H). 

 The inspector reviewed the drilling surveillance database, examined drilling rate changes, 

and permitted and active injection wells while interviewing staff. The inspector received and 

reviewed Texas and New Mexico well database ACCESS files, maps of oil and gas wells around 

WIPP, and well plugging documents. (COB-M2007-H12, -H13, -H15, -H17, -H18, -H21, -H22, 

-H22a, -H22b, and -H23). The inspector verified that DOE tracks and reports the drilling rate 

and the number of Castile brine encounters near WIPP. 
6 

4.5 Monitoring of Subsidence Parameters

 DOE committed to measure subsidence at the WIPP site. This parameter is documented 

as part of the WIPP Underground and Surface Surveying Program, WP 09-ES.01 (COB-M2006-

B). DOE performs subsidence surveys at the site annually during pre-closure operations. The 

results of this program are reported annually in the WIPP Subsidence Monument Leveling 

Survey – 2006, DOE/WIPP 07-2293 (COB-M2007-D). 

 Subsidence staff demonstrated the Office Procedure (Section 2 of WP 09-ES4001 (COBM2006-P)) to the EPA inspector which describes the steps taken to process raw field survey data 

and to calculate final surface elevations published in their annual report (COB-M2007-S1, -S2, -

S3, -S4, and –S5). DOE demonstrated that the subsidence parameter is measured and reported 

yearly. 

5.0 Summary of finding, observation, concerns, and recommendations.

 Based on program documents, interviews, and field demonstrations during the inspection, 

EPA concludes that the monitoring program covers the ten monitoring parameters required by 

EPA’s 1998 Certification Decision. This inspection determined that the monitoring, sample 

collection, and sample/data analysis procedures were complete and appropriate; that staff were 

adequately trained and implemented the procedures adequately; and that appropriate quality 

assurance measures are applied. For these reasons, EPA continues to find that DOE has 

maintained adequate parameter monitoring during the past year and has the procedures and 

requirements in place to sustain their program into the next year. EPA has no findings or 

concerns. 
7 

Attachment A: Inspection Plan and Checklist 

2007 Monitoring Parameter Inspection Plan

Purpose: Verify that the Department of Energy (DOE) can demonstrate that the Waste Isolation 

Pilot Plant (WIPP) is monitoring the parameter commitments made in the documentation to 

support the EPA’s certification decision, in particular CCA, Volume 1, Section 7.2, Table 7.7 

and Appendix MON. This inspection is conducted under the authority of 40 CFR 194, Section 

21. 

This inspection is part of EPA’s continued oversight to ensure that WIPP can, in fact, monitor 

the performance of significant parameters of the disposal system. 

Scope: Inspection activities will include an examination of monitoring and sampling equipment 

both on and off site, and in the underground. A review of sampling procedures and measurement 

techniques may be conducted. Quality assurance procedures and documentation for each of 

these activities will also be reviewed. 

Focal Areas of This Year’s Inspection: 

- What has changed in the monitoring program this past year? 

- What documentation and procedures have changes? 

- Update the monitoring program and results for the past year. 

- Have any monitoring parameters changed? 

Location: This inspection will be held at the WIPP facility location twenty-six miles south east 

of Carlsbad, New Mexico and the surrounding vicinity as needed. 

Duration: The EPA expects to complete its inspection in two days. Each day will begin with an 

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

Expected Date: Week of July 9, 2007. 

Documents For Review: Just like past years provide latest versions of any documentation 

and/or procedures related to your monitoring program as soon as possible. 
8 

Monitoring Commitments – July 2007 Geomechanical Parameters

# Question Comment (Objective Evidence) 

SAT = Satisfactory

Result

1 Does DOE demonstrate that they have 

implemented plans/programs/procedures to 

measure - 

a) Creep Closure; 

b) Extent of Deformation; 

c) Initiation of Brittle Deformation and 

d) Displacement of Deformation Features 

during the pre-closure phase of operations as 

specified in the CCA part of the geomechanical 

monitoring system? 

(CCA, Volume 1, Table 7-7; App MON, Table 

MON-1) 40 CFR 194.42 (c) and (e) 

WIPP Geotechnical Engineering Program 

Plan, (WP 07-01: COB-M2007-C), 

documents plans to measure, report, and the 

QA requirements related to these activities. 

Section 3.0 of WP 07-01 documents the 

geomechanical monitoring program and 

records the activities associated with this 

program. Section 4.0 of WP 07-01 

documents the quality assurance 

requirements for these activities. 

During this inspection site staff demonstrated 

the adequacy of the program and that the 

program produces satisfactory results (COBM2007-G1 to G14. They showed samples of 

remote measurement, sample plots, and staff 

preformed underground manual 

measurements of convergence, borehole 

deformation, fracture mapping, stratigraphic 

mapping and remote measurements. WTS 

continues, as last year, to enhance roof 

control to mitigate the impact of stringers 

anhydrite stringers in new Panels. 

Results of this program are documented 

annually in the Geotechnical Analysis Report 

for each reporting period (DOE/WIPP 07-

3177: COB-M2007-A and -A2). 

The inspector toured and reviewed the 

computer system and databases used to 

collect and process recorded data. 

SAT 

2 Does DOE demonstrate that they have 

implemented an effective quality assurance 

program for item 1 above? 40 CFR 194.22 

During this inspection the EPA inspector 

evaluated the quality assurance program and 

found it to be adequate. 

SAT 

3 Does DOE demonstrate that the results of the 

geotechnical investigations are reported 

annually? (CCA, App. MON, Page MON-10) 

WP 07-01, Section 3.2 requires that analysis 

be performed annually and results are 

published in the annual geotechnical analysis 

report (DOE/WIPP 07-3177). 

SAT 
Monitoring Commitments – July 2007 Hydrological Parameters

# Question Comment (Objective Evidence) Result

1 Does DOE demonstrate that they have 

implemented plans/programs/procedures to 

measure - 

a) Culebra Groundwater Composition; 

b) Change in Culebra Groundwater Flow 

Direction 

during the pre-closure phase of operations as 

specified in the CCA part of WIPP’s 

groundwater monitoring plan? 

(CCA, Volume 1, Table 7-7; App MON, Table 

MON-1) 40 CFR 194.42 (c) and (e) 

WIPP Groundwater Monitoring Program Plan, 

WP 02-1(COB-M2007-B) documents plans to 

measure, document, report, and the QA 

requirements for these activities. WP 02-1 

records the activities associated with this 

program (Section 4), methods used (Sections 5 

and 6), data analysis (Section 7) and reporting 

requirements (Section 8). Section 11.0 of WP 

02-1 documents quality assurance 

requirements. 

Site staff discussed changes to the program 

over the past year (COB-M2007-I4b). Staff 

also explained the new SURFER computer 

code contouring techniques used to develop 

maps to find flow direction in the Culebra 

(COB-M2006-H1 to H24) 

SAT 

2 Does DOE demonstrate that they have 

implemented an effective quality assurance 

program for item 1 above? (CCA, App MON, 

Page MON-22) 40 CFR 194.22 

During this inspection the EPA inspector 

evaluated the quality assurance program and 

found it to be adequate. 

SAT 

3 Does DOE demonstrate that the results of the 

groundwater monitoring program are reported 

annually? (CCA, App. MON, Page MON-22) 

Results are published annual in the Waste 

Isolation Pilot Plant Annual Site 

Environmental Report for 2005 (DOE/WIPP 

06-2225: COB-M2007-I) Chapters 4.3 and 

6.0. 

SAT 
10 

Monitoring Commitments – July 2007 Waste Activity Parameters

# Question Comment (Objective Evidence) Result

1 Does DOE demonstrate that they have 

implemented plans/programs/procedures to 

measure - 

a) Waste Activity? 

(CCA, Volume 1, Table 7-7; App MON, Table 

MON-1) 40 CFR 194.42 (c) and (e) 

WIPP Waste Information System Program and 

Data Management Plan (WP 08-NT.01: COBM2007-E, Section 6.0) describes how the 

WWIS is used to measure and store waste 

activity information. WWIS User’s manual 

(DOE/CBFO 97-2273: COB-M2007-J) 

documents procedures used to gather, store, 

and process waste activity information. Table 

3 of the Annual Change Report 2005/2006, 

(DOE/WIPP 06-3317: COB-M2007-K) 

updates waste activity annually. 

WWIS staff demonstrated the use of the 

WWIS and generated numerous reports 

(COB-M2007-W1 to W7). Such as the 

Nuclide Report which summaries isotopes 

emplaced at WIPP. These activities 

demonstrate that waste activity is adequately 

monitored. 

SAT

2 Does DOE demonstrate that they have 

implemented an effective quality assurance 

program for item 1? (CCA, App WAP, page 

C-30) 40 CFR 194.22 

During this inspection the EPA inspector 

evaluated the quality assurance program and 

found it to be adequate. 

SAT 

3 Does DOE demonstrate that the results of the 

waste activity parameters are reported 

annually? (CCA Volume, Section 7.2.4 

Reporting) 

WP 08-NT.01 Section 6, page 11 “Regulatory 

Reporting” documents that results are reported 

annually and DOE/WIPP 06-3317 verifies that 

results are published annually. 

SAT 
Monitoring Commitments – July 2007 Drilling Related Parameters

# Question Comment (Objective Evidence) Result

1 Does DOE demonstrate that they have 

implemented plans/programs/procedures to 

measure - 

a) Drilling Rate; and 

b) Probability of Encountering a Castile Brine 

Reservoir? 

(CCA, Volume 1, Table 7-7; App MON, Table 

MON-1) 40 CFR 194.42 (c) and (e) 

The Delaware Basin Drilling Surveillance 

Plan, (WP 02-PC.02: COB-M2006-F, not 

changed since last year), documents the 

program planned to measure, document, 

report, and the QA requirements for these 

activities. Section 7.0 of WP 02-PC.02 

documents quality assurance requirements. 

The Delaware Basin Drilling Database 

Upgrade Process (WP 02-EC3002: COBM2007-F) documents the process used to 

update databases with information from 

various commercial and state sources. 

Drilling rate and Castile brine encounter data 

are updated annually in the Delaware Basin 

Monitoring Annual Report (DOE/WIPP 06-

2308: COB-M2007-H) in Sections 2.5 and 

2.6. 

Staff discussed changes during the past year 

(COB-M2007-I4a and –I4b). Reported on 

brine encounters, drilling rate calculations, 

and provided maps of drilling activities near 

WIPP (COB-M2007-H11 to H24). They 

demonstrated that DOE is adequately 

monitoring these parameters. 

SAT 

2 Does DOE demonstrate that they have 

implemented an effective quality assurance 

program for item 1 above? (CCA, App DMP, 

page DMP-9) 40 CFR 194.22 

During this inspection the EPA inspector 

evaluated the quality assurance program and 

found it to be adequate. 

SAT 

3 Does DOE demonstrate that the results of the 

drilling related parameters are reported 

annually? (CCA Volume, Section 7.2.4 

Reporting; App DMP, page DMP-9) 

WP 02-PC.02 Section 6.0 documents that 

results are reported annually. DOE/WIPP 99-

2308 verifies that these parameters are 

updated and reported annually. 

SAT 
12 

Monitoring Commitments – July 2007 Subsidence Measurements

# Question Comment (Objective Evidence) Result

1 Does DOE demonstrate that they have 

implemented plans/programs/procedures to 

measure - 

a) Subsidence measurements? 

(CCA, Volume 1, Table 7-7; App MON, Table 

MON-1) 40 CFR 194.42 (c) and (e) 

WIPP Underground and Surface Surveying 

Program (WP 09-ES.01: COB-M2006-B), 

documents the program used to measure, 

document, report, and the QA requirements 

for these activities. Subsidence Survey Data 

Acquisition Report technical procedure (WP 

09-ES4001:COB-M2006-P) documents the 

process for acquiring subsidence data, 

updating the database, and publishing the 

annual subsidence report. The WIPP 

Subsidence Monument Leveling Survey - 

2006 (DOE/WIPP 07-2293: COB-M2007-D) 

documents that DOE reports this parameter 

annually and the results of this program. 

Staff demonstrated that procedures are 

adequately implemented when they showed 

how the raw field data collected is reduced to 

useful survey data and how annual results are 

calculated. They demonstrated that subsidence 

is adequately monitored at the site. 

SAT 

2 Does DOE demonstrate that they have 

implemented an effective quality assurance 

program for item 1? 40 CFR 194.22 

During this inspection the EPA inspector 

evaluated the quality assurance program and 

found it to be adequate. 

SAT 

3 Does DOE demonstrate that the results of the 

subsidence measurements are reported 

annually? (CCA Volume, Section 7.2.4 

Reporting) 

WP 09-ES.01 Section 3.3.2 documents that 

results are reported annually. DOE/WIPP 07-

2293 demonstrates that results are published 

annually. 

SAT 
Attachment B: Documents Reviewed