### 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

1Contents

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

2Figures

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

Figure 2 Arrangement of dispos ed waste in a room ...................................... 9

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

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

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

.

31.0 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 Pl ant (WIPP) near Carlsbad, New Mexico, from July 14 to July 16, 2009, in accordance with 40 CFR 194.21. Th e WIPP is a disposal system for defense-related transuranic (TRU) waste as define d by the WIPP Land Withdrawal Act. 1 EPA certified that WIPP complies with the Agency’s radioactive wast e disposal regulations (Subparts B and C of 40 CFR Part 191) on May 18,

1998.

The purpose of this annual inspection is to determin e 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 s ite’s ability to receive, process, and emplace contact-handled (CH) and remote-handled (RH) TR U wastes within the repository, the emplacement of magnesium oxide (MgO) backfill in appropriate amount s to fulfill DOE commitments and requirements, and the maintenance of records pertaining to wast e shipping, packaging, and emplacement, including the electronic WIPP Waste Information System (WWIS). EPA examined selected activiti es, 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 im plemented its planned change to redu ce 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 ar e adequate, that cellul osic, plastic and rubber (CPR) material is appropriately track ed 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 WI PP Waste Handling User’s Manual (WP 05-WH.01).

EPA did not identify any findings or concerns during this inspecti on. 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.

42

. 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 ye ar has been emplaced in th e underground facility in the manner specified in DOE’s Comp liance Certification Application an d other approvals. EPA performs the inspection under au thority of 40 CFR 194.21, which authorizes the Agency to inspect WIPP during its operational period to verify continued complian ce with EPA’s WIPP Compliance Criteria and the certification decision of May 18, 1998. Emplacement of wast e and backfill, in partic ular, is relevant to compliance because the emplacement method supports th e 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 a pprovals, maintenance of relevant waste packaging records, including the electronic WIPP Waste Information System (WWIS) and the verification of appropriately impl emented 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 contra ct to DOE, and the majority of waste related

activities onsite ar e 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, OBSE RVERS, AND PARTICIPANTS

The inspection team consisted of four EPA st aff. Thomas Kesterson of the New Mexico Environment Department also observed the inspection activities. A partial list of inspection participants is provided in Table A.

5Table A Inspection Partic ipants

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 PERFO RMANCE 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 mile s 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 informa tion addressing program st atus, 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 pack ages 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 data base, to verify correct waste info rmation 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 in spectors 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 pr eliminary observations at a close-out meeting on the

6afternoon 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, Lo s Alamos National Laboratory (LANL) in New Mexico, Idaho National Laboratory (INL), Hanf ord Site in Washington, Rocky Fl ats Environmental Technology Site (RFETS) in Colorado, Savannah River Site (SRS) in Sout h 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 drum s assembled in groups of seven called a Seven Pack, 100 gallon drums for supercompact ed waste, and Ten Drum Overpacks (TDOP). RH wastes from INL, ORNL, and SRS ha ve been emplaced in the WIPP.

The repository is subdivided into panels, each pane l 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 alwa ys placed on the floor of the room, occupying the bottom and middle position of a waste column. SWBs and drums are em placed in no particular order with most wastes emplaced as received. The waste columns are in a seri es 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).

7Figure 1

Typical RH and CH TRU Mixed Waste Disposal Configuration

8Figure 2 Figure 2 Illustrates the arrang ement 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 bore holes drilled (BH 083, BH 084) to emplace RH containers, and observed the Horizontal Emplacement/Ret rieval Equipment set up to emplace a RH canister in BH083 (Figure 4).

While underground in Room 7, Panel 5, EPA inspect ors selected recently emplaced CH waste packages for review. The inspector read the shipme nt identification numbers di rectly off the emplaced containers (See Figure 3 for CH loca tions). 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 Empl acement Report and Container Data Report

Site of Waste Container Origin Identifier Borehole Number

LANL LA04 080

LANL LA13 081

LANL LA03 082

9On July 16 at CBFO, WTS personnel and EPA inspector s exam ined 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 Re port and the MgO safety factor calculation on the Emplace Containe rs 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 us ed in the repository as b ackfill, as specified in DOE’s Compliance Certification Applic ation (CCA). EPA requires DOE to maintain an MgO safety factor to ensure that adequate MgO is chem ically available to control the chemis try 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 EP A’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 deve loping 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 great er 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 sh ift, the WHE must electronically veri fy the safety factor of 1.2 using WWIS waste database. Electronic MgO r ecord 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 reflec t the 1.2 safety factor and the use of 3,000-lb. supersacks as necessary.

10However, EPA noted that the procedure has not been updated to reflect that paper form s for recording MgO placement are now found in WP 05-WH1025. Specificall y, 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 de termined that this discrepancy did not rise to the leve l of a concern, because WHEs are using the correct, updated paper forms (from WP 05-WH1025) to record wa ste 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 drum s are Ten Drum Overpacks (TDOPs), black barrels are 100-gallon drums with supercompacted waste, standard waste boxes, and standard 55-gallon drum 7-packs.

11Figure 4 Equipment prepared for RH waste emplacement in Room 6 of Panel 5

12Figure 5 Emplaced RH Waste selected for review

7.0 COMPARISON WITH INVENTORY LIMITS

In presentation at the opening m eeting of the inspection, EPA was provided with data for emplaced waste, including total activities of the ten EPA-tr acked 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 wast e 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 10 7 kg. The minimum limit is 2 x 10 7 kg iron. With total metals at

1.61 x 10 7 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 an d rubber (CPR) materials. In the or iginal CCA, DOE estimated the limit

for CPR was 2.2 x 10 7 kg, establishing the limit EPA required DOE to meet. In the subsequent performance assessment baseline calculations, DOE added packagi ng materials to the calculations, and now the CPR limit

for WIPP is 2.4 x 10 7 kg (see Table C). CPR values are tracked on a per container basis and the current CPR

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

As of this inspection the WIPP contained almost 4.6 x 10 6 kg of CPR in waste and 1.4 x 10 6 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 10 5 kg of CPR. This is a total of 6.4 x 10 6 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 speci fied plans documented in the CCA. EPA concludes that DOE’s emplacement activities a nd 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 a nd 2, both closed since th e change took place in

March 2009.

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

docum ented 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 revisi ons to facility Technical Procedures WP 05-

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

15Attachment A

W IPP 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 speci fied in DOE’s Compliance Certification Application and other approvals. The objective ev idence 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 peri od to verify continued compliance with EPA’s WIPP Compliance Criteria and the cer tification decision of May 18, 1998.

- Is DOE emplacing waste in the underground at WI PP 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: demonstrati on 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 elect ronic WIPP Waste Information system (WWIS) and the verification of appropriately implem ented quality assurance practices. Th e 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 ac tivities and documentation since last year’s inspection?

- What changes have taken place to MgO emplacem ent 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 la test version of pertin ent documentation and/or procedures related to CH and RH wast e emplacement, MgO, WWIS, training, etc.

16Attachment B

Number of TRU Waste Containers Em placed 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

17Attachment B (continued)

Number of TRU Waste Containers Em placed 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 drum s but with some salt-filled dunnage drums.

Argonne National Laboratory - East (A NL-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 m 3 ) 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

18Attachment C

Materials Emplaced in WIPP as of July 16, 2009 (Table configuration modified for simplification)

CH WASTE:

MP Material Type Material Descri ption 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

19Attachment 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)

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

20Attachment E

Excerpt from Panel 5, Room 7 Da ily Report, including MgO Balance

21Attachment F

Procedures Examined

22Attachment G EPA Emplacement Inspection Checklist – Ju ly 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’sCompliance 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

233 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. Reco rds 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.

247 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

2512 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

2618 Verify documentation of procedures for abnormal operating conditions, and documentation of training for contingencies. Abnormal operating and emer gency 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 cont ainer number, shipment number, and emplacement information in the underground. Satisfactory

2720 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

2829 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.

M MgOReq. = MT*(6)* [m

c +m g +1.7*m p ]/(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