DOCKET NO: A-98-49

 Item: II-B3-111

Emplacement Inspection Report

EPA INSPECTION No. EPA-WIPP-7.09-14c 

OF THE 

WASTE ISOLATION PILOT PLANT 

July 14 to July 16, 2009 

U. S. ENVIRONMENTAL PROTECTION AGENCY 

Office of Radiation and Indoor Air 

Center for Waste Management and Regulation 

1200 Pennsylvania Avenue, NW 

Washington, DC 20460 

September 2009

1
 Contents

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

 

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

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

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

5.0 Waste Emplacement/WWIS............................................................... 7 

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

7.0 Comparison with Inventory limits...........................................................13 

8.0 Summary of Results...........................................................................14 

Attachments

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

Attachment B – 

Number of Waste Containers Emplaced as of July 16, 2009..................................... 17 

Attachment C - Material Emplaced in WIPP as of July 16, 2009............................... 19 

Attachment D –Summary of MgO Safety Factor Calculations................................. 20 

Attachment E – Excerpt from Panel 5, Room 7 Daily Report, including MgO Balance.... 21 

Attachment F – Procedures Examined.............................................................. 22 

Attachment G – Inspection Checklist............................................................... 23 

Tables

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

Table B Waste Containers Reviewed During Inspection................................ 9 

Table C Emplaced CPR Quantities as of July 16, 2009.................................. 14 

2
Figures

Figure 1 Typical RH and CH TRU Mixed Waste Disposal Configuration ............ 8

Figure 2 Arrangement of disposed waste in a room ...................................... 9 

Figure 3 Photo of disposed waste in Room 7 of Panel 5................................. 11

Figure 4 Equipment prepared for RH waste emplacement in Room 6 of Panel 5.... 12 

Figure 5 Emplaced RH Waste selected for review......................................... 13 

. 

3
1.0 EXECUTIVE SUMMARY 

The U.S. Environmental Protection Agency (EPA or the Agency) conducted an inspection of the U.S. 

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

14 to July 16, 2009, in accordance with 40 CFR 194.21. The WIPP is a disposal system for defense-related 

transuranic (TRU) waste as defined by the WIPP Land Withdrawal Act.1

 EPA certified that WIPP complies 

with the Agency’s radioactive waste disposal regulations (Subparts B and C of 40 CFR Part 191) on May 18, 

1998. 

 The purpose of this annual inspection is to determine that waste sent to WIPP during the past year has 

been emplaced in the underground facility in the manner specified in DOE’s Compliance Certification 

Application and other approvals. The inspection reviews the site’s ability to receive, process, and emplace 

contact-handled (CH) and remote-handled (RH) TRU wastes within the repository, the emplacement of 

magnesium oxide (MgO) backfill in appropriate amounts to fulfill DOE commitments and requirements, and 

the maintenance of records pertaining to waste shipping, packaging, and emplacement, including the 

electronic WIPP Waste Information System (WWIS). EPA examined selected activities, such as RH and CH 

waste processing, waste emplacement activities, and record keeping. During this year’s inspection EPA 

placed specific emphasis on the emplacement and tracking of the magnesium oxide (MgO) engineered 

barrier, due to the fact that DOE implemented its planned change to reduce the MgO safety factor to 1.2 in 

the interim since EPA’s most recent (July 2008) emplacement inspection. 

EPA concluded that DOE’s emplacement activities are adequate, that cellulosic, plastic and rubber 

(CPR) material is appropriately tracked and recorded, that MgO balances are calculated properly, and that 

MgO is emplaced properly. Although EPA observed the use of proper paper documentation in the 

underground, a small discrepancy was found in the WIPP Waste Handling User’s Manual (WP 05-WH.01). 

 EPA did not identify any findings or concerns during this inspection. EPA observed that procedures 

found in Revision 4 of the WIPP Waste Handling User’s Manual (WP 05-WH.01) do not reflect recent 

changes to WP 05-WH1011, Rev. 33, CH Waste Processing, and WP 05-WH1025, Rev. 1, CH Downloading 

and Emplacement. EPA recommends that DOE update WP 05-WH.01 to assure consistency throughout its 

procedures.

 1

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

Public Law 104-201. 

4
2.0 INSPECTION PURPOSE AND SCOPE

The purpose of this annual inspection is to verify that contact-handled (CH) and remote-handled (RH) 

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

the manner specified in DOE’s Compliance Certification Application and other approvals. EPA performs 

the inspection under authority of 40 CFR 194.21, which authorizes the Agency to inspect WIPP during its 

operational period to verify continued compliance with EPA’s WIPP Compliance Criteria and the 

certification decision of May 18, 1998. Emplacement of waste and backfill, in particular, is relevant to 

compliance because the emplacement method supports the models that DOE used in the WIPP performance 

assessment. 

 

Activities within the scope of this inspection included: demonstration of the WIPP site’s ability to 

receive, process, and emplace CH and RH TRU wastes within the repository, the use of magnesium oxide 

(MgO) backfill in amounts to fulfill certification requirements and other approvals, maintenance of relevant 

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

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

documents related to these activities is an important part of the inspection process. The WIPP site is 

operated by Washington TRU-Solutions (WTS) under contract to DOE, and the majority of waste related 

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

examined during this inspection is provided in Attachment G. 

3.0 INSPECTION TEAM, OBSERVERS, AND PARTICIPANTS 

 The inspection team consisted of four EPA staff. Thomas Kesterson of the New Mexico 

Environment Department also observed the inspection activities. A partial list of inspection participants is 

provided in Table A.

5
Table A 

Inspection Participants

INSPECTION TEAM 

MEMBER POSITION AFFILIATION 

Chuck Byrum Inspector EPA ORIA 

Tom Peake Inspector EPA ORIA 

Nick Stone Inspector EPA Region 6 

Jonathan Walsh Inspector EPA ORIA 

CBFO / WTS PERSONNEL

Rey Carrasco CBFO 

Art Chavez WRES 

Dan Ferguson CBFO 

Dave Kump WTS 

Dave Speed WTS 

David Squires WTS 

Gene Valett WTS 

Mike Strum WWIS 

4.0 PERFORMANCE OF THE INSPECTION 

The inspection took place on July 14-16, 2009, at DOE’s Carlsbad Field Office (CBFO) and at the 

Waste Isolation Pilot Plant (WIPP) facility, which is located approximately 26 miles south east of Carlsbad, 

New Mexico. The opening meeting with CBFO and WTS personnel was held on the morning of July 14, 

2009. Several DOE and WTS staff presented information addressing program status, updates and changes 

since the last EPA emplacement inspection in July 2008. 

 

 EPA inspectors accompanied CBFO and WTS personnel into the underground repository on the 

morning of July 15, in order to examine waste packages and MgO that had been emplaced in Panel 5. 

Inspectors reviewed paper records documenting that waste emplacement and MgO tracking were conducted 

in accordance with procedures. Inspectors selected several containers and recorded their numbers (see 

Figure 5 for container locations); the records for these containers were examined both in the repository, and 

later using the WWIS computer database, to verify correct waste information is recorded by DOE. WTS 

personnel explained how waste is handled and emplaced, and answered EPA questions. 

During the afternoon of July 15, EPA inspectors visited the CH and RH waste handling areas 

aboveground. On July 16, inspectors reviewed record-keeping procedures with WWIS data administrators, 

and WTS personnel generated various reports for the inspectors at the Carlsbad Field Office, including 

Waste Emplacement Reports and Waste Container Data Reports for RH and CH waste containers observed 

in the underground the day prior. EPA presented its preliminary observations at a close-out meeting on the 

6
afternoon of July 16. 

5.0 WASTE EMPLACEMENT/WWIS

To date, the wastes received at the repository are contact-handled transuranic wastes from Argonne 

National Laboratory-East (ANL-E) in Illinois, Los Alamos National Laboratory (LANL) in New Mexico, 

Idaho National Laboratory (INL), Hanford Site in Washington, Rocky Flats Environmental Technology Site 

(RFETS) in Colorado, Savannah River Site (SRS) in South Carolina, the Nevada Test Site (NTS) in Nevada, 

and the Oak Ridge National Laboratory (ORNL) in Tennessee. These wastes are received and emplaced in 

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

called a Seven Pack, 100 gallon drums for supercompacted waste, and Ten Drum Overpacks (TDOP). RH 

wastes from INL, ORNL, and SRS have been emplaced in the WIPP. 

The repository is subdivided into panels, each panel consisting of seven rooms. At the time of the 

inspection, CH waste was being emplaced in Panel 5, Room 7 and RH waste in the walls of Panel 5, Room 6. 

CH waste containers are stacked in columns (waste stacks) combining SWBs, drum packs, and TDOPs (see 

Figures 2 and 3). TDOPs are always placed on the floor of the room, occupying the bottom and middle 

position of a waste column. SWBs and drums are emplaced in no particular order with most wastes 

emplaced as received. The waste columns are in a series of staggered rows, with a row consisting of three 

columns that span the distance of a disposal room from left to right (Figure 2). Remote-handled waste is 

placed in the walls on eight foot centers (Figures 1, 4, and 5). 

7
Figure 1 

Typical RH and CH TRU Mixed Waste Disposal Configuration 

8
Figure 2 

Figure 2 Illustrates the arrangement of disposed contact-handled waste in underground. 

Represented are stacks of seven-packs of drums and standard waste boxes. 

 In Panel 5, Room 6 inspectors observed boreholes drilled (BH 083, BH 084) to emplace RH 

containers, and observed the Horizontal Emplacement/Retrieval Equipment set up to emplace a RH canister 

in BH083 (Figure 4). 

While underground in Room 7, Panel 5, EPA inspectors selected recently emplaced CH waste 

packages for review. The inspector read the shipment identification numbers directly off the emplaced 

containers (See Figure 3 for CH locations). The containers selected are identified in Table B below. 

Table B 

Waste Containers Reviewed During Inspection (Panel 5, Room 7) 

 CH Waste (Field verified) 

 Site of Waste Container 

 Origin Identifier Container Type 

 INL(RF) BN10278350 Ten Drum Overpack (TDOP) 

 INL BN10287121 100-gallon drum 

 INL BN10267854 100-gallon drum 

 INL NT070679R Standard Waste Box 

RH Waste (Panel 5, Room 6) Waste Emplacement Report and Container Data Report 

 Site of Waste Container 

 Origin Identifier Borehole Number

 LANL LA04 080 

 LANL LA13 081 

 LANL LA03 082 

9
 

On July 16 at CBFO, WTS personnel and EPA inspectors examined reports from the following WIPP Waste 

Information System (WWIS) modules: 

• Characterization Module, linked to the Waste Container Data Report 

• Certification Module, linked to the Acceptance/Rejection Report 

• Shipping Module, linked to the Shipment Summary Report 

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

calculation on the Emplace Containers Underground (Attachments G). 

All records were found to contain required waste stream, container, and emplacement information. 

6.0 MAGNESIUM OXIDE BACKFILL

 Magnesium oxide (MgO) is the engineered barrier used in the repository as backfill, as specified in 

DOE’s Compliance Certification Application (CCA). EPA requires DOE to maintain an MgO safety factor 

to ensure that adequate MgO is chemically available to control the chemistry of each room after closure. 

EPA approved lowering the required safety factor to 1.2 from 1.67 in a letter dated February 11, 2008, 

requiring the emplacement of sufficient MgO to react with 1.2 times the amount of carbon present in the 

repository. Conditions of EPA’s agreement stipulated that DOE must ensure a minimum reactivity of 96% 

for the MgO emplaced, and maintain the safety factor on a room-by-room basis. DOE instituted this change 

in March 2009. During the opening meeting, Gene Valett gave a presentation outlining DOE’s change to the 

1.2 safety factor, which included developing a laboratory verification of MgO reactivity, field testing five 

supersacks filled with 3000 pounds of MgO (as opposed to 4200 pounds), releasing version 6.4 of the WWIS, 

updating WTS technical procedures, and designating an MgO Administrator. 

Process steps guiding MgO placement and documentation in the underground have been removed 

from the current revision of WP 05-WH1011, CH Waste Processing, Rev. 33, and placed in a new document, 

WP 05-WH1025, CH Waste Downloading and Emplacement, Rev. 1. Specifically, Section 3.0, Backfill, 

establishes procedures to maintain a safety factor of 1.2 or greater per room on a daily basis. Waste 

Handling Engineers (WHE) may record the quantity and placement of MgO electronically using a WWIS bar 

code reader, or manually via paper forms if a bar code reader is unavailable. The appropriate forms (CH 

Waste Downloading and Emplacement Data Sheet and Supersack/BRT Emplacement Data Sheet) are 

included as Attachements 1 and 3 of WP 05-WH1025. While in the underground repository, EPA inspectors 

verified that the proper, current paper forms were used to track MgO emplacement in Panel 5, Room 7 and 

that MgO was emplaced on top of the CH waste stacks as stipulated. No 3,000 pound sacks other than those 

used for field tests had been emplaced in the underground at the time of the inspection, due to the high CPR 

content of supercompacted CH waste that is currently being emplaced. 

 At the conclusion of each shift, the WHE must electronically verify the safety factor of 1.2 using 

WWIS waste database. Electronic MgO record management is addressed in the WIPP Waste Handling 

Operations WWIS User's Manual, WP 05-WH.01, Rev. 4. Sections 6.2.5 and 9.3.3, and Attachment 1 have 

been appropriately updated to reflect the 1.2 safety factor and the use of 3,000-lb. supersacks as necessary. 

10
However, EPA noted that the procedure has not been updated to reflect that paper forms for recording MgO 

placement are now found in WP 05-WH1025. Specifically, Steps 6.2.5.D; 8.1.2; and Attachment 1, Steps 6, 

8, 9 and 10.2 erroneously refer the user to WP 05-WH1011. EPA inspectors determined that this 

discrepancy did not rise to the level of a concern, because WHEs are using the correct, updated paper forms 

(from WP 05-WH1025) to record waste and MgO in the underground. 

Checklist items 12-17 and 27-30 specifically relate to MgO management and demonstrate that DOE 

has appropriate processes in place to ensuring MgO is properly emplaced. 

Figure 3. Photo of disposed waste in Panel 5, Room 7. 

DOE is emplacing waste stacked 2-3 containers high topped with MgO Supersacks. Figure 3 shows all 

container types being shipped to date. Large drums are Ten Drum Overpacks (TDOPs), black barrels are 

100-gallon drums with supercompacted waste, standard waste boxes, and standard 55-gallon drum 7-packs. 

11
Figure 4 

Equipment prepared for RH waste emplacement in Room 6 of Panel 5

12
Figure 5 

Emplaced RH Waste selected for review 

7.0 COMPARISON WITH INVENTORY LIMITS 

In presentation at the opening meeting of the inspection, EPA was provided with data for emplaced 

waste, including total activities of the ten EPA-tracked radionuclides, total weights of ferrous and nonferrous metals, and the CPR/MgO balance by room, as of June 30, 2009. More detailed emplacement data 

were provided during subsequent correspondences with WWIS staff. 

 EPA has established limits for certain waste components at WIPP by approving performance 

assessment inventory estimates. Some limits, such as for iron and other metals, are minimum limits. The 

amount of iron and steel are now at 1.58 x 107

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

1.61 x 107 kg, the repository now contains approximately 80% of the minimum amount stipulated in the 

certification. 

 Other waste component limits are maximum limits. Of special concern is the maximum limit on the 

total amount of cellulosic, plastic and rubber (CPR) materials. In the original CCA, DOE estimated the limit 

for CPR was 2.2 x 107

 kg, establishing the limit EPA required DOE to meet. In the subsequent performance 

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

for WIPP is 2.4 x 107

 kg (see Table C). CPR values are tracked on a per container basis and the current CPR 

13
values as of July 16, 2009 are listed in Table C. 

As of this inspection the WIPP contained almost 4.6 x 106 kg of CPR in waste and 1.4 x 106 kg of 

CPR in packaging material. In addition, emplacement CPR, such as the slipsheets used to aid the 

emplacement of the containers, accounts for another 3.5 x 105 kg of CPR. This is a total of 6.4 x 106 kg of 

cellulosic, plastic and rubber material. The mass of rubber materials now account for only 3.4% of the total 

mass of CPR, compared to 5% in 20098, 4.7% in 2007, and 7% in 2006. The WIPP currently contains 

approximately 29% of its maximum limit for CPR. The repository held 24% of its limit for CPR in 2008, 

and 21% of the limit in 2007. 

Table C 

Emplaced CPR Quantities as of July 16, 2009

Waste CPR: Emplacement CPR: 

Type Weight (kg) Type Weight (kg) 

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

Cellulosic 1,733,077 Cellulosic 46,435 

Plastic 2,569,409 Plastic 302,390 

Rubber 291,318 

Total 4,593,804 (kg) 348,824 (kg) 

Packaging CPR: MgO CPR: 

Type Weight (kg) Type Weight (kg)

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

Cellulosic 837,120 Cellulosic 44,395 

Plastic 571,457 Plastic 49,997 

 Total 1,408,577 (kg) 94,347(kg) 

Grand Totals: 

Cellulosic + Plastic = 6,154,234 

Rubber = 291,318 

Total CPR = 6,445,552 (kg)

8.0 SUMMARY OF RESULTS

 The inspectors reviewed emplacement operations, WTS procedures, and records associated with 

selected containers. The surface processing of CH and RH waste as well as underground operations were 

reviewed and found to be adequate, according to specified plans documented in the CCA. EPA concludes 

that DOE’s emplacement activities and records are adequate, that CPR is appropriately tracked, and that 

DOE’s planned change to an MgO safety factor of 1.2 has been implemented properly. Specifically, the 

CPR/MgO excess factor is calculated correctly and regularly on a room-by-room basis, MgO is emplaced as 

needed, and that steps have been taken to assure that MgO reactivity is retained. The current safety factor 

was above the mandated 1.2 for Panel Four, Rooms 1 and 2, both closed since the change took place in 

March 2009. 

 

14
EPA did not identify any findings or concerns during this inspection. Its only observation, 

documented in detail in section 6.0 of this report, is that WP 05-WH.01, WIPP Waste Handling Operations 

WWIS User's Manual, Rev. 4, is inconsistent with recent revisions to facility Technical Procedures WP 05-

WH1011 and WP 05-WH1025. EPA recommends that the procedure be updated for consistency. 

15
Attachment A 

WIPP Emplacement Inspection Plan for the Year 2009 

Purpose: 

 The purpose of this inspection is to determine if waste sent to WIPP during the past year has been 

emplaced in the underground facility in the manner specified in DOE’s Compliance Certification Application 

and other approvals. The objective evidence is the documentation that EPA can use to verify that DOE is 

conducting its operation appropriately. 

 EPA is performing this inspection under the authority of 40 CFR 194.21, which authorizes the 

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

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

 

- Is DOE emplacing waste in the underground at WIPP in a manner specified in DOE’s Compliance 

Certification Application (EPA Air Docket A-93-02, Item II-G-01, and associated documents)? 

- Is DOE emplacing waste in the underground at WIPP in a manner to assure that the 1.2 safety factor is 

maintained. 

Scope: 

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

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

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

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

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

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

Focal Areas for this Year’s Inspection: 

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

inspection? 

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

Location: 

 The inspection will be held at DOE’s WIPP facility located twenty-six miles southeast of Carlsbad, 

New Mexico and the Carlsbad Field Office (CBFO) in Carlsbad. Inspection activities will include 

examination of the underground facilities, review of records related to waste emplacement, and other 

information as needed. 

Duration: 

 The EPA expects to complete its inspection in about two days plus an initial meeting. Each full day 

will begin with an opening meeting at 8:00 a.m. and end no later than 5:00 p.m. with a closeout session. 

Expected Date: Week of July 13, 2009 

Documents For Review: 

 Electronically provide for this inspection the latest version of pertinent documentation and/or 

procedures related to CH and RH waste emplacement, MgO, WWIS, training, etc. 

16
Attachment B

Number of TRU Waste Containers Emplaced at WIPP as of 07/16/2009

Contact Handled Waste 

 

Site 

 

 

 

 Container 

 Type

100 

gallon 

55 

gallon 

12” Pipe 

overpack 

S100 

Pipe 

over

pack 

S300 

Pipe 

over 

pack 

Std 

Waste 

Box 

TDOP 85 gallon 

overpack 

2009 

total 

2008 

total 

2007 

total 

2006 

total 

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

Hanford 0 7104 2163 0 0 350 257 0 9874 9474 7390 6159 

INL 19018 23294 0 0 0 1950 2345 0 46607 35271 30722 23564 

LANL 0 8604 398 211 10 731 1 0 9955 8405 7046 5040 

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

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

ORNL 0 112 0 0 0 0 0 0 112 0 

RFETS 0 15460 21174 0 0 3910 4 0 40584 40548 40548 40548 

SRS 0 4157 0 0 5703 2169 0 7029 5885 4755 4173 

WIPP 0 2 0 0 0 1 0 5 8 4 3090 3006 

TOTAL 19018 61534 23735 211 10 7661 4788 5 116962 102416 96929 85868 

 

17
Attachment B (continued)

Number of TRU Waste Containers Emplaced at WIPP as of 07/16/2009

Remote Handled Waste Containers 

 

Site 2009 

Total 

2008 

Total 

ANL-E 11 

RL 199 

INL 161 

LANL 14 

NTS 

ORNL 4 

RFETS 

SRS 15 

WIPP 

TOTAL 243 161 

 

NOTE: The drums listed for WIPP consist of two drums of site generated waste, two drums from RFETS that were overpacked 

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

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

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

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

(RFETS) Oak Ridge National Laboratory (ORNL) 

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

Waste Isolation Pilot Plant (WIPP) 

Drums = 55 gallon (208 liter or 0.208 m3

) steel drums Pipe Overpack = 55 gallon drum pipe 

overpack except for the S100 

SWB = Standard Waste Box TDOP = ten drum overpack 

Dunnage = inert drums used to complete waste assemblies 

18
Attachment C

Materials Emplaced in WIPP as of July 16, 2009 

(Table configuration modified for simplification) 

CH WASTE: 

MP Material Type Material Description Material Weight (kg) 

1 Waste Iron Based Metal/Alloys 6,044,986.86 

2 Waste Aluminum Based Metal/Alloys 43,263.82 

3 Waste Other Metal/ Alloys 284,958.05 

4 Waste Other Inorganic Materials 1,249,654.69 

6 Waste Cellulosics 1,733,074.17 

7 Waste Rubber 291,317.38 

8 Waste Plastics 2,540,453.10 

9 Waste Solidified Inorganic Material 6,062,180.96 

10 Waste Solidified Organic Material 947,751.31 

12 Waste Soils 141,371.28 

13 Steel - 

Packaging Steel Container Materials 11,206,328.12 

14 Plastic - Plastic /Liners Container 

 Packaging Materials 571,198.68 

15 Cellulosic - Cellulosic Packaging 

Packaging Materials 837,115.57 

18 Emplacement Cellulosic Emplacement 

 Material 46,434.77 

20 Emplacement Plastic Emplacement 1,713,017.90 

 Material 

RH Waste

1 Waste Iron Base Metal Alloys 22,383.96 

6 Waste Cellulosics 3.10 

8 Waste Plastics 28,956.16 

13 Steel Steel Container Materials 132,440.59 

Packaging 

14 Plastic Plastic/ Liners Container 

 Packaging Materials 258.34 

15 Cellulosic Cellulosics Packaging 4.26 

 Packaging Materials 

MgO

16 Emplacement Magnesium Oxide 24,627,581.57 

18 Emplacement Cellulosic Emplacement Mat’l 44,349.75 

20 Emplacement Plastic Emplacement Mat’l 49,997.25 

19
Attachment D

Summary of MgO Safety Factor Calculations as of 6/30/09 

Source: WWIS Data Support, Opening Meeting Slides 

 MgO Waste CPR Safety 

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

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

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

 6 222,885 101,210 86,116 1.44 

 5 222,885 160,047 79,213 1.56 

 4 228,600 128,597 85,525 1.51 

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

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

 1 617,220 311,843 138,330 2.14 

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

 6 982,980 461,528 209,305 2.20 

 5 988,820 498,970 197,609 2.29 

 4 977,265 518,555 220,912 2.17 

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

 2 965,835 733,025 165,412 2.62 

 1 691,515 416,679 186,200 1.71 

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

 6 954,405 876,558 228,033 1.95 

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

 4 960,120 899,470 255,054 1.79 

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

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

 1 662,940 722,043 183,072 1.76 

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

 6 925,830 945,599 267,494 1.71 

 5 946,785 890,039 265,295 1.71 

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

 3 1,015,365 745,955 285,770 1.70 

 2 933,176 933179 374,333 1.22 

 1 676,275 554,822 265,912 1.24 

5 7 438,150 477,527 204,476 0.92 

 6 0 8,044 6,011 0.00 (RH Only) 

==================================================== 

20
Attachment E 

Excerpt from Panel 5, Room 7 Daily Report, including MgO Balance 

21
Attachment F

Procedures Examined

22
Attachment G 

EPA Emplacement Inspection Checklist – July 14-16, 2009

 # Questions: Comments and Objective Evidence Results

Waste Emplacement 

1 Is waste being emplaced in the 

underground facility in the 

manner specified in DOE’s 

Compliance Certification/ ReCertification or other relevant 

documentation? 

Yes. Procedure WP 05-WH1025, Rev. 26, CH Waste 

Downloading and Emplacement, Section 2, describes 

the CH emplacement procedures. Visual verification 

of the emplaced waste in Rows 94 through 96 of Panel 

5, Room 7 confirmed waste emplacement in 

accordance with facility procedure and CCA 

documentation . 

RH processing procedures for 72-B (WP 05-WH1710, 

WP 05-WH1725) and 10-160-B (WP 05-WH1722) 

containers are consistent with the approach discussed 

in the CCA documentation. Emplacement in the 

repository walls with borehole plugs was verified 

during inspection of the underground. 

Satisfactory 

2 Are CH waste containers stacked 

in columns appropriately given 

the type of container? 

Yes. In WP 05-WH1025, CH Downloading and 

Emplacement, a note at step 2.25 specifies appropriate 

stacking of CH container types. Attachment 2 of the 

same procedure specifies payload assembly 

positioning. Visual verification confirmed adherence 

to procedure (e.g. TDOPs placed in bottom position of 

waste columns.) 

Satisfactory 

23
3 Are records adequate? 

Randomly select 3-4 CH and 2-3 

RH waste containers to verify 

records for waste approval, 

shipment, and receipt. 

Yes. TRU Waste Receipt WP 08-NT3020, Rev.18 

describes the process. Records produced are Uniform 

Hazardous Waste Manifest, TRU Waste Receipt 

Checklist, Shipment Summary Report, RH waste 

Processing Data Sheet, Radiological Survey Report, 

and Waste Emplacement Report. CH waste produces 

comparable records. EPA reviewed records and found 

the records to be adequate and traceable. 

Selected Containers: 

CH Waste (Panel 5, Room 7, Rows 94-96) 

- Ten Drum Overpack (TDOP), BN10278350, 

INL(RF) 

- 100-gallon drum, BN10287121, INL 

- 100-gallon drum, BN10267854, INL 

- Standard Waste Box NT070679R, INL 

 

RH Waste (Panel 5, Room 6) 

- Borehole 080, LA04, LANL 

- Borehole 081, LA13, LANL 

- Borehole 082, LA03, LANL 

Satisfactory 

4 Is DOE properly emplacing 

backfill material (magnesium 

oxide [MgO]) with the waste 

packages? 

Are supersacks placed on top of 

waste stacks according to 

procedure? 

Yes. 4200-pound supersacks were observed to be 

emplaced on top of each waste assembly. WP 05-

WH1025, CH Waste Downloading and Emplacement, 

Section 3.0, establishes procedure for emplacement of 

MgO. 

Satisfactory 

5 Verify documentation for the 

containers listed in item 3 - waste 

generator site transmittal of waste 

to WIPP, WIPP approval, 

shipment certification for 

transport to WIPP, shipment 

initiation documentation, 

shipment received at WIPP 

records, waste emplaced in the 

underground, and placement of 

engineered barrier [MgO]. 

Inspectors examined paper records maintained 

underground and electronic records kept aboveground 

for the selected containers. Documentation was 

determined to be adequate. 

Satisfactory 

RH Waste 

Emplacement Questions 

6 Are RH containers approved for 

receipt, received, processed, and 

emplaced properly? 

Yes. Inspection of the underground and RH handling 

area showed procedures to be in agreement with WP 

05-WH1710, Rev. 13, 72-B RH Processing, and WP 

05-WH1725, Rev. 3, RH Waste Downloading and 

Emplacement. 

Satisfactory. 

24
7 Are RH containers appropriately 

tracked? 

Where is the information? 

--In the WWIS, what report 

--During the receipt/transfer 

process where is it recorded? 

--In the underground? 

Yes. Appropriate information is found in the WWIS 

Waste Container Data Report RP0360, and on the 

underground facility map maintained by the Waste 

Handling Engineers in the underground. 

Satisfactory. 

8 Content of RH canisters 

--pick 1 to 3 canisters 

See Item 3 above. WWIS Waste Container Data 

Report RP0360 generated and reviewed for each 

canister. 

Satisfactory 

9 Volume and mass and/or 

concentration of important waste 

components and radionuclides 

(RH and CH)? 

Are they within statutory and 

regulatory limits? 

Detailed description of nuclide information is included 

in the Waste Container Data Reports generated. 

Yes. 

Satisfactory 

10 Are RH boreholes closed 

properly? 

(Note: also see #9 for tracking of 

RH in the U/G) 

Recently emplaced borehole plugs, and plugs prepared 

for emplacement, were observed by inspectors in the 

underground to be in accordance with WP 05-

WH1725, Rev. 3, RH Waste Downloading and 

Emplacement. 

Satisfactory 

11 Is a photographic record made of 

the RH canister number during 

emplacement and retained in the 

permanent record? 

Yes. The canister ID number is verified by two 

operators during cask transfer via closed-circuit 

television, and the tapes are kept as a record, in 

accordance with procedure 05-WH1710, 72-B RH 

Processing, section 8.24 . 

Satisfactory 

Question: Procedure 

Is there a schematic hierarchy of 

DOE’s written procedures, 

including the current revision and 

effective date?

Yes. A schematic hierarchy of documents related to 

site operation and monitoring was presented in the 

opening conference by Larry Madl. QNMIS 

electronically catalogues procedural documents, 

indicating past, current, and planned revisions. 

Satisfactory 

25
12 Have DOE procedures been 

updated to reflect EPA’s 

acceptance of the planned change 

of the MgO safety factor to 1.2? 

Partially. WP 05-WH1025, CH Waste Downloading 

and Emplacement, Rev. 1, Section 3.0, Backfill, 

establishes procedures to maintain a safety factor of 

1.2 or greater per room on a daily basis. Procedures in 

the WWIS User’s Manual, WP-05-WH.01, Rev. 4, 

Sections 6.2.5 and 9.3.3, and Attachment 1 have been 

updated to reflect the 1.2 safety factor and the use of 

3,000-lb. supersacks as necessary. Sections 6.2.5 and 

8.1.2, however, reference attachments to WP 05-

WH1011 which have been moved to WP 05-WH1025. 

EPA inspectors determined that this did not rise to the 

level of a concern because WHEs were observed to be 

using the correct, updated paper forms (from WP 05-

WH1025) to record waste and MgO in the 

underground, but recommend that the documents be 

brought into agreement. 

Observation 

13 Are both CPR and MgO 

calculated and tracked on a roomby-room basis? 

Yes. Calculations are performed by the Waste 

Handling Engineer at the conclusion of each shift, 

through the WWIS, using the WIPP Emplacement 

Software MgO Balance Report or Daily Report, as 

required by WP 05-WH1025, CH Waste Downloading 

and Emplacement, Rev. 1, Section 3.0, Backfill. 

Satisfactory 

14 Are sampling and analytical 

procedures in place to ascertain 

that emplaced MgO maintains a 

minimum of 96% reactivity? 

Yes. Specification D-0101, Prepackaged MgO 

Backfill, Rev. 8 and WP 05-WH1105, MgO Sample 

Records Management, Rev. 0, set forth analytical and 

document management procedures to verifying that 

each shipment of MgO maintains a 96 +/- 2% 

reactivity. 

Satisfactory 

15 Is the acceptance of the MgO 

backfill material from the supplier 

documented? 

Yes. WP 05-WH1105, MgO Sample Records 

Management, Rev. 0, Sec. 2.0 requires each shipment 

to be numbered, and the MgO supplier to provide an 

Analysis of Shipment and a sample under Chain of 

Custody for each shipment. Supersacks in the 

underground were observed by inspectors to be 

marked with unique ID numbers, traceable to their 

original shipments. 

Satisfactory 

16 For the MgO needed for high 

CPR, are there procedures or 

documentation for the WHE or 

WHM (or other appropriate 

personnel) identifying when and 

where additional MgO is needed? 

Partially. Procedures are found in the WIPP Waste 

Handling Operation WWIS User’s Manual, WP 05–

WH.01, Revision 4, 2/11/08, Attachment 1, Special 

Requirements for Additional MgO. This procedure 

correctly shows methods for emplacing adequate MgO 

to achieve a safety factor of 1.2, however, in steps 6, 

7, and 9, it incorrectly cites WP 05-WH1011 instead 

of WP 05-WH1025. EPA recommends that this 

procedure be brought up to date. 

Observation 

17 Is there documentation that 

identifies how MgO should be 

placed with high CPR waste? 

Yes. WP 05-WH1025, CH Waste Downloading and 

Emplacement, Rev. 1 Attachment 3, Supersack/BRT 

Emplacement Data Sheet; and WP 05-WH1058, CH 

Waste Handling Abnormal Operations, Rev. 0, Sec. 

4.0, BRT Emplacement 

Satisfactory 

26
18 Verify documentation of 

procedures for abnormal 

operating conditions, and 

documentation of training for 

contingencies. 

Abnormal operating and emergency procedures were 

reviewed, including but not limited to those listed 

below. 

WP 04-CO, Conduct of Operations, Rev. 10 identifies 

notification policies, supervision and training 

procedures, and required reading (Management Policy 

1.30). 

WP 02-EC3506, Environmental Incident Reporting, is 

the Management Control Procedure for reporting 

releases, and includes statutory requirement charts for 

notifications and decision flowcharts. 

WP 05-WH1058, CH Waste Handling Abnormal 

Operations, includes instructions for recovering from a 

torn slip sheet, moving emplaced waste, returning 

waste to surface, and emplacing BRTs. Specifies that 

“Abnormal operations of a large scope (e.g. overpack 

and retrieval) will have specific plans developed.” 

WP 05-WH1758, RH Waste Handling Abnormal 

Operations, includes instructions for operating the Hot 

Cell Crane in response to a hoist, trolley, bridge or 

grapple failure, installing and removing the Waste 

Transfer Machine Assembly (WTMA) wheels, 

retrieving a loaded RH –TRU 72-B Cask from the 

Transfer Cell, returning a loaded 10-160B Cask to a 

generator site and resetting the Transfer Cell Light 

Curtain. 

WP 12-9, WIPP Emergency Management Program, is 

the top-level document outlining emergency response 

procedures and responsibilities, includes training 

requirements for response roles. 

WP 05-WH4401, Waste Handler Operator Event 

Response, includes alarm, alert, and exit procedures. 

WP 12-ER3906, Categorization and Classification of 

Operational Emergencies includes tables of 

procedures for emergency notifications and 

classification of events. 

WP 12-HP4000, Emergency Radiological Control 

Responses, provides guidance for responding to an 

actual or suspected breach of a TRU container, 

contamination found outside controlled areas, 

radiation levels exceeding the limits set in WP 12-5. 

Satisfactory 

# Question: Records/WWIS

19 Does the WWIS adequately 

document waste shipment and 

emplacements information for 

waste containers selected? (Item 3 

above) CH, RH 

Yes. In the Waste Emplacement Report, the WWIS 

adequately documents waste shipment and 

emplacement information. WWIS Waste 

Emplacement Reports, and WWIS Waste Container 

Data Reports contain container number, shipment 

number, and emplacement information in the 

underground. 

Satisfactory 

27
20 Is DOE maintaining records of 

waste shipments and 

emplacement properly? CH, RH 

Yes. WWIS Waste Container Data Reports and 

underground maps were reviewed by inspectors to 

verify that records are properly maintained for both 

CH and RH waste containers. Emplacement is tracked 

properly in the underground using both WWIS 

barcode readers and paper forms as necessary. 

Satisfactory. 

21 Do the characterization module, 

certification module, shipping 

module, and inventory module 

adequately record the required 

information? 

The Waste Emplacement Report (WER) and Waste 

Container Data Report records contain the container 

number, shipment number, emplacement data and 

underground location. WIPP staff queried the WWIS, 

and EPA inspectors verified that the WER recorded 

this information correctly. 

Satisfactory 

22 Do records verify that contact 

handled waste container surface 

doses fall within statutory 

requirements? Where are CH 

surface dose records maintained? 

Yes. CH surface dose measurements are recorded in 

the Waste Container Data Report. Dose limits for 

each of the containers examined by EPA inspectors 

(listed in Item 3) were below statutory limits. 

Satisfactory 

23 Characterization Module - 

Review a WWIS Waste Container 

Data Report. Does this report 

adequately record the Waste 

Stream Profile Form information? 

Yes. Inspectors reviewed Waste Container Data 

Reports for all containers inspected, and found them to 

contain Waste Stream IDs, as well as all necessary 

radiological and chemical profile information. 

Satisfactory 

24 Characterization Module - Does 

the data administrator verify that 

DOE/CBFO has granted 

certification and transportation 

authority to the generator/shipper 

site prior to review of 

generator/shipper characterization 

data? 

Yes. The Waste Stream Profile Form Review and 

Approval Program, WP 08-NT.03, Section 8.4 

documents that “...allows DA (data administrator) 

approval of certified container data prior to shipment 

of containers...”. The inspectors verified these 

approvals. 

Satisfactory 

25 Shipping Module - Review the 

Shipment Summary Report. Does 

the report correctly record the 

containers shipped? CH, RH 

Yes. Inspectors reviewed Shipment Summary Reports 

for the selected containers and found them to be 

adequate. 

Satisfactory 

26 Inventory Module - Review the 

Waste Emplacement Report. 

Does this report adequately record 

the date of receipt, and disposal 

locations of containers? CH, RH 

Yes. See Item 21. Satisfactory 

27 Is MgO implementation 

appropriately documented? 

Where is it described? 

Yes. See Items 12, 13, 16 and 17. Satisfactory 

28 Is DOE properly tracking the 

MgO backfill so that the MgO 

safety factor can be accurately 

calculated? 

Yes. See Item 13. Satisfactory 

28
29

29 Is DOE assuring that the 1.2 

safety factor being maintained on 

a room basis? 

Does the WWIS accurately 

calculate the safety factor and 

recommend the proper amount of 

MgO to emplace? 

Where is this been verified? 

Yes. WP 05-WH1025, CH Waste Downloading and 

Emplacement, Section 3.0 requires the WHE to 

calculate the MgO balance at the end of each shift. 

See Item 13. 

EPA inspectors reviewed InSEI Matrix Requirement 

MB-REQ-0024, to verify that the WWIS software 

calculates MgO excess appropriately. 

MMgOReq. = MT*(6)* [mc+mg+1.7*mp]/(162g/mole) 

*(2.2046lbs/kg)*(kg/100g)*(40.3/mole) 

Satisfactory 

30 Is there documentation that 

describes how the site uses the 

MgO module of the WWIS? 

Yes. Instructions are found in the WP 05-WH.01, 

Rev. 4, WIPP Waste Handling Operations WWIS 

Users Manual 

Satisfactory