1

DOCKET NO: A-98-49 

Item: II-B3-102

Emplacement Inspection Report

EPA INSPECTION No. EPA-WIPP-7.07-10c 

OF THE 

WASTE ISOLATION PILOT PLANT 

July 10 – 12, 2007 

U. S. ENVIRONMENTAL PROTECTION AGENCY 

Office of Radiation and Indoor Air 

Center for the Waste Isolation Pilot Plant 

1310 L. Street, N. W. 

Washington, DC 20005 

September 2007
2

 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............................................................... 8 

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

7.0 RH Operation................................................................................. 12 

8.0 Comparison with Inventory limits...........................................................13 

9.0 Summary of Results...........................................................................14 

Attachments

Attachment A – Inspection Plan.......................................................................15 

Attachment B – 

Number of Waste Containers Emplaced as of July 9, 2007.......................................16 

Attachment C - Material Emplaced in WIPP as of July 12, 2007................................18 

Attachment D – WWIS Administration Status Display .........................................19 

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

Attachment F – Room 3, Panel 3 MgO Safety Calculations for August 27, 2006 ...........21 

Attachment G – Procedures Examined................................................................22 

Attachment H – Inspection Checklist.................................................................24 

Attachment I – Documents and Records Received During the Inspection.......................29 
3

Tables

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

Table B Waste Containers Reviewed During Inspection..................................10 

Table C Emplace CPR Quantities as of July 9, 2009.......................................14 

Figures

Figure 1 Demonstration of radiation measurement in a plugged RH borehole...........7

Figure 2 Arrangement of disposed waste in a room .........................................8 

Figure 3 Typical RH and CH TRU Mixed Waste Disposal Configuration...............9

Figure 4 Photo of disposed waste in a room.................................................11 

Figure 5 Emplaced CH waste in Room 6 Panel 4............................................12 

Figure 6 RH Boreholes in the wall with disposed containers at 8 feet interval..........12 

Figure 7 RH Boreholes recently drilled for emplacement..................................13 
4

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 10 to July 12, 2007, 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 the 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 was 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. A specific focus of this inspection 

was to review the site’s ability to receive, process, and emplace contact-handled and remotehandled TRU wastes within the repository, the emplacement 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). 

EPA looked at selected activities, such as RH and CH waste processing, waste emplacement 

activities, and record keeping. 

EPA concluded that DOE=s emplacement activities are adequate, that CPR is appropriately 

tracked and recorded, that additional MgO is calculated properly, and that MgO is emplaced 

properly. While DOE does not necessarily maintain an MgO safety factor above 1.67 for 

operational efficiency while loading waste in a room, DOE does place enough MgO before room 

closure is completed to assure that the safety factor is maintained for each room. 

 EPA did not identify any findings or concerns during this inspection. EPA does have one 

recommendation: that DOE retain a photographic record that verifies the canister identification 

number of the remote-handled canister as it is transferred from the transportation cask to the 

facility cask and include the record with the permanent record package. 

 

1WIPP Land Withdrawal Act, Public Law 102-579, Section 2(18), as amended by the 1996 WIPP LWA 

Amendments, Public Law 104-201. 
5

2.0 INSPECTION PURPOSE AND SCOPE

 The purpose of this annual inspection was to determine if 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 performed the inspection under 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. 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. An additional purpose of this inspection was to verify that RH waste is emplaced in 

accordance with the plan and procedures specified in the Compliance Certification Application 

(CCA) and demonstrated during the WIPP RH startup inspection of January 9 – 11, 2007. 

 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, 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 the documents related to these processes was an important part of the 

inspection. 

 

 The WIPP site is operated by Washington TRU-Solutions (WTS) under contract to DOE. 

The majority of waste related activities onsite are described by or controlled through WTS 

procedures. A list of WTS procedures examined for this inspection is provided in Attachments 

G and I. 

3.0 INSPECTION TEAM, OBSERVERS, AND PARTICIPANTS 

 The inspection team consisted of three EPA staff. Thomas Kesterson and Dean Foster of 

the New Mexico Environmental Department and Jerry Fox of Pecos Management Services also 

observed the inspection activities. A partial list of inspection participants is provided in Table A. 
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Table A 

Inspection Participants

4.0 PERFORMANCE OF THE INSPECTION 

The inspection took place on July 10 - 12, 2007, 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 10, 2007. Several DOE and WTS staff presented information 

addressing program status, updates and changes since the last EPA emplacement inspection in 

2006 : primarily CH-RH waste processing, MgO emplacement and waste record keeping. 

 

 The EPA inspectors accompanied CBFO and WTS personnel into the underground 

repository on the morning of July 11, in order to examine waste packages and MgO that had 

been emplaced in Panel 4. Inspectors selected several containers and recorded their numbers 

(see Figure 5 for container locations); the records for these containers were examined later in the 

WWIS computer database to verify correct waste information is recorded by DOE. The WTS 

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

INSPECTION TEAM 

MEMBER POSITION AFFILIATION 

Chuck Byrum Inspector EPA ORIA 

Tom Peake Inspector EPA ORIA 

Shankar Ghose Inspector EPA ORIA 

 

CBFO / WTS PERSONNEL

Mike Oliver DOE/CBFO 

Art Chavez WRES 

Randy Britain WTS 

Dave Kump WTS 

Dave Speed WTS 

John Vandekraats WTS 

Linda Frank-Supka WTS 

Mike Strum WWIS 

Ed Flynn WTS 
7

 

Figure 1 

Demonstration of radiation measurement in a plugged RH borehole 

 In Room 5 Panel 4 inspectors observed the planning and arrangement of boreholes drilled 

(BH 044, BH 097) to emplace RH containers. Measurement of possible radiation leakage from a 

plugged borehole was also demonstrated (Figure 1). The measuring device recorded a maximum 

reading of 0.1 mrem per hour as explained by the operator. 

 The inspectors examined waste emplacement operations in the underground and waste 

that had been recently placed in the repository. The inspectors also reviewed records 

documenting that waste emplacement and MgO tracking were conducted in accordance with 

procedures. To date, the waste received at the repository are contact-handled (CH) transuranic 

wastes from Argonne National Laboratory-East (ANL-E) in Illinois, Los Alamos National 

Laboratory (LANL) in New Mexico, Idaho National Engineering and Environmental Laboratory 

(INEEL), Hanford Site in Washington, Rocky Flats Environmental Technology Site (RFETS) in 

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

Nevada. These wastes are 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 are currently shipped to WIPP from INL. 

 The inspectors also observed RH processing operations in the Cask Unloading Area, Hot 

Cell and Radiation Monitoring areas of the RH bay of the waste handling building and compared 

the activities to the requirements as described in 72-B RH Processing, WP 05-WH1710. 

 Inspectors reviewed the procedures with WWIS data administrators. Mike Strum (data 

administrator) generated various reports for the inspectors at the Carlsbad Field Office. These 

included Shipment Summary Reports, Waste Emplacement Reports and Waste Container Data 

Reports for RH and CH waste. 
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5.0 WASTE EMPLACEMENT/WWIS 

Figure 2 

Figure 2 Illustrates the arrangement of disposed waste in underground. 

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

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

time of the inspection, CH waste was being emplaced in Room 6 of Panel 4. Waste containers 

are stacked in columns (waste stacks) combining SWBs, drum packs, and TDOPs (see Figure 3, 

4, and 5). 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 

and 3). Remote-handled waste is placed in the walls on eight foot centers (Figures 3, 6, and 7). 
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Figure 3 

Typical RH and CH TRU Mixed Waste Disposal Configuration 
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While underground in Room 6, Panel 4, the EPA inspector selected recently emplaced 

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

the emplaced containers (See Figure 5 for CH locations). The containers selected are identified 

in Table B below. 

Table B 

Waste Containers Reviewed During Inspection (Panel 4, Room 6) 

 CH Waste (Field verified) 

 Site of Waste Container 

 Origin Identifier Container Type 

 LANL LASB00184 Standard Waste Box 

 INEEL BN10173001 100-gallon drum 

 INEEL BN10147029 55-gallon drum 

RH Waste (Panel 4, Room 5) Waste Emplacement Report and Container Data Report 

 Site of Waste Container 

 Origin Identifier Borehole Number

 ANL-E ID0015 079 

 ANL-E ID0028 022 

 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 the required information. EPA recommends that a 

permanent photographic record of the RH canister number be placed in the RH record package to 

enhance traceability and ensure that correct containers are processed. 

6.0 MAGNESIUM OXIDE BACKFILL

 Magnesium oxide (MgO) is used in the repository as backfill, as specified in DOE’s 

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

factor (e.g. excess MgO) of 1.67 or greater, which means that MgO in amounts of at least 1.67 

times the amount of carbon will always be in the repository to control chemical conditions and 

remove carbon dioxide gas. 
11

 WTS Technical Procedure WP 05-WH1011, CH Waste Processing, Sections 5.0, 6.0 and 

Attachment 1 (CH Waste Processing Data Sheet), details steps guiding MgO placement and the 

required documentation to assure that MgO placement has been accomplished correctly. Section 

6.2 of WP 05-WH1011 states the Waste Handling Engineer (WHE) is to verify that the safety 

factor is greater than or equal to 1.67. Attachments to WP 05-WH1011 record the quantity and 

location of emplaced MgO for later entry into the WWIS waste database. 

 Checklist items 4, 6, 7 and 12 specifically relate to MgO management and demonstrates 

DOE has an appropriate process for ensuring that MgO is properly emplaced. In addition to the 

requirement in WTS Technical Procedure WP 05-WH1011, DOE addresses the addition of 

MgO in the WIPP Waste Handling Operations WWIS User's Manual, WP 05-WH.01, Rev. 2, 

Attachment 1 - Special Requirements for Additional MgO. 

Figure 4. Photo of disposed waste in a room. 

DOE is emplacing waste stacked 2-3 containers high topped with MgO Supersacks. This picture 

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. 
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Figure 5 

Emplaced CH Waste in Room 6 Panel 4 

7.0 RH Operation 

 

The first shipment of RH waste was received on January 23, 2007 and was emplaced on 

January 28, 2007. A preliminary emplacement forecast indicates that DOE plans to dispose a 

total of 93 containers in Rooms 3 through 7 in Panel 4. However, this forecast may vary due to 

weather, regulatory or procedural delays and generator site shipping rates. 

Figure 6 

RH Boreholes in the wall with disposed containers at 8 feet interval

 
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EPA reviewed various aspects of RH waste “operational MODES” (“MODES are established to 

provide a safe, structural approach to facility operation”, DOE /WIPP-06-3178, page 1-7). These 

include RH Waste handling, RH Waste Storage and RH Standby Modes. EPA’s review included 

surface RH processing operations conducted prior to emplacement of the RH container in the 

underground boreholes and underground RH processing activities. EPA reviewed the 

requirements associated with these processes and found them adequate. 

 

Figure 7 

RH Boreholes recently drilled for emplacement 

8.0 COMPARISON WITH INVENTORY LIMITS 

 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 5.38 x 107

 kg. The minimum limit is 2 

x 107 kg iron. With over 300,000 kg of aluminum and other non-ferrous metals, the WIPP has 

already exceeded 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 CCA, DOE 

estimated the limit for CPR was 2.2 x 107 kg and this is the limit EPA has required DOE to meet. 

However, 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 values as of July 

9, 2007 are listed in Table C. 
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 As of this inspection the WIPP contained 2.9 x 106 kg of CPR in waste and 1.3 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 0.3 x 106

 kg of CPR. This is a total of 

nearly 4.6 x 106 kg of cellulosic, plastic and rubber material. Most of this is split between the 

cellulosic and plastic materials; the mass of rubber materials now account for about 4.5% of the 

total mass of CPR, compared to 7% in 2006. Thus, the WIPP is approaching 21% of the CPR 

limit. 

Table C 

Emplaced CPR Quantities as of July 9, 2007

(Source: Opening Meeting Handout) 

Waste CPR: Emplacement CPR: 

Type Weight (kg) Type Weight (kg) 

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

Cellulosic 1,002,795 Cellulosic 74,557 

Plastic 1,714,192 Plastic 260,560 

Rubber 205,068 

Total 2,922,055 (kg) 335,117 (kg) 

Packaging CPR: 

Type Weight (kg) Grand Totals: 

Cellulosic 829,226 Cellulosic + Plastic = 4,377,113 

Plastic 495,783 Rubber = 205,068 

 Total 1,325,009 (kg) 4,582,181(kg) 

9.0 SUMMARY OF RESULTS

 The inspectors reviewed emplacement operations and associated documentation for 

selected containers. EPA concluded that DOE’s emplacement activities are adequate, that CPR 

is appropriately tracked, the safety factor is calculated properly, additional MgO is added as 

needed, and that all MgO is emplaced properly. DOE noted that the current safety factor was 

above the mandated 1.67 for closed rooms since the tracking officially began with Room 1, 

Panel 2 and Room 7, Panel 3 at the time of the inspection (see Attachment E). 

 

 The surface processing of RH and the underground operation of RH container 

emplacement were explained and found to be according to specified plans documented in CCA. 

EPA did not identify any findings or concerns during this inspection. However, EPA 

recommends that DOE maintain a permanent photographic record of the RH canister number as 

it is removed from the transportation cask. 

 
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Attachment A 

July 10-12, 2007 Emplacement Inspection Plan

 

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. 

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. 

Location: 

 The inspection will be held at the DOE’s WIPP facility located twenty-six miles 

southeast of Carlsbad, New Mexico and the Carlsbad Field Office (CBFO). 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: July 10 through July 12, 2007. 

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 07/09/2007

Contact Handled Waste 

 

Site 

 

 

 

 Container 

 Type

100 

gallon 

55 

gallon 

Pipe 

overpack 

S100 Std 

Waste 

Box 

TDOP 85 gallon 

overpack 

Dunnage 

drum 

Dunnage 

Std 

Waste 

Box 

2007 

total 

2006 

total 

ANL-E 0 318 0 0 0 12 0 4 0 334 334 

RL 0 4682 2128 0 270 232 0 78 0 7390 6159 

INEEL 8628 17883 0 0 1700 1942 0 569 0 30722 23564 

LANL 0 5719 295 13 350 0 0 669 0 7046 5040 

LLNL 0 678 0 0 2 0 0 8 0 688 688 

NTS 0 1805 0 0 14 0 0 8 0 1827 1827 

RFETS 0 15460 21174 0 3910 4 0 529 0 41077 41077 

SRS 0 2380 0 0 474 1901 0 0 0 4755 4173 

WIPP 0 2 0 0 0 0 2 3073 13 3090 3006 

TOTAL 8628 48927 23597 13 6720 4091 2 4938 13 96929 85868

 
17

Attachment B (continued)

Number of TRU Waste Containers Emplaced at WIPP as of 07/09/2007

Remote Handled Waste 

 

Site 2007 

Total 

ANL-E 

RL 

INEEL 35 35 

LANL 

NTS 

RFETS 

SRS 

WIPP 

TOTAL 35 35 

 

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) 

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 12, 2007 

(Table configuration modified for simplification) 

CH WASTE: 

MP Material Type Material Description Material Weight (kg) 

1 Waste Iron base Metal Alloys 4,409,840.85 

2 Waste Aluminum Based Metal /Alloys 34,829.55 

3 Waste Other Metal/ Alloys 267,080.21 

4 Waste Other Inorganic Materials 1,033,089.91 

6 Waste Cellulosics 1,006,250.90 

7 Waste Rubber 205,468.94 

8 Waste Plastics 1,716,987.26 

9 Waste Solidified Inorganic Material 5,489,821.21 

10 Waste Solidified Organic Material 301,181.81 

12 Waste Soils 9,282.60 

13 Steel - 

Packaging Steel Container Materials 9,463,057.44 

14 Plastic - Plastic /Liners Container 

 Packaging Materials 496,012.31 

15 Cellulosic - Cellulosic Packaging 

Packaging Materials 829,256.18 

18 Emplacement Cellulosic Emplacement 

 Material 40,388.44 

20 Emplacement Plastic Emplacement 1,346,614.10 

 Material 

RH Waste

1 Waste Iron Base Metal Alloys 2,551.70 

13 Steel Steel Container Materials 19,646.00 

Packaging 

14 Plastic Plastic/ Liners Container 

Packaging Materials 41.08 

MgO

16 Emplacement Magnesium 

Oxide 19,078,590.11 

18 Emplacement Cellulosic Emplacement 

 Material 34,299.90 

20 Emplacement Plastic Emplacement 

 Material 39,947.40 
19

Attachment D
20

Attachment E 

 Summary of MgO Safety Factor Calculations 
21

Attachment F

Room 3, Panel 3 MgO Safety Factor Calculation for August 27, 2006 
22

Attachment G

Procedures Examined

> COB-E2007-2 and -S8 : CH Waste Processing, Technical Procedure WP 05-WH1011, Revision 26; 

Effective Date: March 28, 2007 

> COB-E2007-18 : Waste Stream Profile Form Review and Approval Program, WP 08-NT.03, Revision 

8, October 18, 2006 

> COB-E2007-17 : TRU Waste Receipt, Management Control Procedure, WP 08-NT3020, Revision 13, 

Effective Date: November 16, 2006 

> COB-M2007-J : WIPP Waste Information System User's Manual WWIS Version 5.4a, DOE/CBFO 

97-2273, Rev. 12, March 2007 

> COB-E2007-16 and –S14 : WIPP Waste Handling Operations WWIS User’s Manual, WP 05-WH.01 

Revision 2; Effective Date: October 5, 2006 

> COB-M2007-L1 : WIPP Contact Handled (CH) Waste Documented Safety Analysis DOE/WIPP-95-

2065, Revision 10, November 2006 

> COB-M2007-L2 : WIPP RH Waste Documented Safety Analysis DOE/WIPP-06-3174, Revision 0, 

March 2006 

> COB-E2007-25 : WIPP RH Technical Safety Requirement DOE/WIPP-06-3178, Revision 0, March 

2006 

> COB-E2007-S18 : Specification for Prepackaged MgO Backfill, Specification, D-0101, Revision 7, 

Revision Date: May 12, 2005 

> COB-E2007-1 : Conduct of Operations WP 04-CO, Revision 7, Effective Date: October 24, 2006 

> COB-E2007-3 : Horizontal Emplacement and Retrieval Equipment Assembly, Technical Procedure, 

WP05-WH1700, Revision 4, Effective Date: February 14, 2007 

> COB-E2007-22 : Road Cask Transfer Car Operation, Technical Procedure, WP 05-WH1701, 

Revision 9, Effective Date: October 31, 2006 

> COB-E2007-23 : Facility Cask Transfer Car 41-H-003 Operation, Technical Procedure, WP 05-

WH1704, Revision 6, Effective Date: January 19. 2006 

> COB-E2007-24 : RH Canister Transfer System, Technical Procedure, WP 05-WH1705, Revision 6, 

Effective Date: June 27, 2006 

> COB-E2007-4 : RH-TRU 72-B Trailer Unloading, Technical Procedure, WP 05-WH1709, Revision 

10, Effective Date: May 16, 2007 
23

> COB-E2007-5: RH Processing 72-B, Technical Procedure, WP 05-WH1710, Revision 8, Effective 

Date: May 15, 2007 

> COB-E2007-6 : RH–TRU 72-B Cask Operation, Technical Procedure, WP 05-WH1712, Revision 2, 

Effective Date: August 1, 2006 

> COB-E2007-7 : Facility Cask and Facility Cask Rotating Device, Technical Procedure, WP 05-

WH1713, Revision 6, Effective Date: October 4, 2006

> COB-E2007-8 :RH Cask Preparation Station 41-Z-076, Technical Procedure, WP 05–WH1714, 

Revision 1, Effective Date: June 21, 2006 

> COB-E2007-10 : Cask Unloading Room Shield Door Operation, Technical procedure, WP 05–

WH1717, Revision 6, Effective Date: August 23, 2006

> COB-E2007-11 : CNS 10-160 B Trailer Unloading, Technical Procedure, WP 05–WH1718, Revision 

5, Effective Date: February 27, 2007 

> COB-E2007-12 : 10-160 B RH Processing, Technical Procedure, WP 05-WH1722, Revision 8, 

Effective Date: March 27, 2007 

> COB-E2007-9 : CNS 10-160B Cask Operation, Technical Procedure, WP 05-WH1716, Revision 3, 

Effective Date: November 2, 2006 

> COB-E2007-13 : Surface RH Transuranic Mixed Waste Handling Area Inspections, Technical 

Procedure, WP 05-WH1744, Revision 8, Effective Date: February 28, 2007 

> COB-E2007-14 : 10-160B Shielded Insert Installation and Removal, Technical Procedure, WP 05-

WH1752, Revision 3, Effective Date: July 10. 2006 

> COB-E2007-15 : RH Waste Handling Abnormal Operations, Technical Procedure, WP 05-WH1758, 

Revision 4, Effective Date: May 17, 2007 

> COB-E2007-19 : Categorization and Classification of Operational Emergencies for RH Waste, 

Management Control Procedure, WP 12-ER3905, Revision 1, Effective Date: February 13, 2007 

> COB-E2007-20 : Hazardous Material Spill and Release Response, Emergency Response Procedure, 

WP12-ER 4902, Revision 9, Effective Date: December 4, 2006 

> COB-A2007-D : Consequence Assessment and Dose Projection, Technical Procedure, WP12-ER4916, 

Revision 10, Effective Date: July 12, 2006 

> COB-E2007-21 : Radiological Surveys, Technical Procedure, WP12–HP1100, Revision 10, Effective 

Date: December 14, 2006 
24

Attachment H 

2007 EPA Emplacement Inspection Checklist

#IIt # Questions: Comments and Objective Evidence Results

Question: 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 for CH. Procedure WP 05-WH1011, Rev. 26, CH 

Waste Processing, Steps 4 to 7, pages 25 through 29

describe the waste emplacement process. Visual 

verification of the emplaced waste in Row 93 and 95

of Panel 4, Room 6 was conducted. SWB (LA 

SB00184), a 55 gallon (BN 10147029) and a 100 

gallon drum (BN1017301) were included in these 

rows. 

Yes for RH. RH processing procedures for 72-B (WP 

05-WH1710) and 10-160-B (WP 05-WH1722) 

containers are consistent with the approach discussed 

in the CCA documentation. 

Satisfactory

2 Are CH waste containers stacked 

in columns appropriately given 

the type of container? 

Yes, waste is being emplaced appropriately. Procedure 

WP 05-WH1011, Attachment 4, Waste Emplacement 

Report Data Sheet. The waste stacking arrangement 

was verified during the inspection in Room 6 Panel 4. 

Satisfactory

3 Are records adequate? Randomly 

select three CH and two RH waste 

containers to verify records for 

waste approval, shipment, and 

receipt. 

Yes. TRU Waste Receipt WP 08-NT3020, Rev.13 

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. See RH Doc 

Packages (COB-E2007-S6) and (COB-E2007-S7) for 

example. CH waste produces comparable records. 

EPA reviewed records and found the records to be 

adequate and traceable. 

Selected Containers: 

CH -LASB00184 (standard waste box), BN10147029 

(55-gal), BN10173001 (100–gal) (see Figure 5) 

RH -ID0015, ID0028 

Satisfactory

4 Is DOE properly emplacing 

backfill material (magnesium 

oxide [MgO]) with the waste 

packages? That supersacks are 

placed on top of waste stacks 

according to procedure? 

Yes. Procedure WP 05-WH1011, Rev. 26, CH Waste 

Processing, Section 5.0, requires MgO to be placed on 

each waste column. While underground the inspectors 

observed that each waste column had a MgO 

supersack emplaced (Figure 5). 

Satisfactory
25

5 Are RH boreholes closed 

properly? 

(Note also see #9 for tracking of 

RH in the U/G) 

Yes, Correct borehole plug emplacement is described

in 72-B RH Processing, WP 05–WH1710, Sections 

19 and 20. Monitoring of smears is also described in 

this document (Section 20.37). The inspector 

observed emplaced plugs, and radiation measurements

(Figure 1). After plug emplacement the maximum 

radiation reading in BH-42 was 0.1 mrem/ hour. 

Satisfactory

6 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 

backfill [MgO]. 

The inspector examined documentation related to 

selected containers - CH -LASB00184 (standard waste

box), BN10147029 (55-gal), BN10173001 (100 – gal) 

RH -ID0015, ID0028. Inspectors verified that these

records exist for these containers and determined that 

the documentation is adequate.

Satisfactory

7 Is the acceptance of the MgO 

backfill material from the supplier 

documented? 

Yes. Record of MgO specification from the supplier

is available (see MgO Analysis 0702-1007, COBE2007-S3). The inspectors examined these documents

and found then to be adequate. 

Satisfactory

RH Waste 

Emplacement Questions 

8 Are RH containers approved for 

receipt, received, processed, and 

emplaced properly? 

Yes. RH processing procedures for 72-B (WP 05-

WH1710) and 10-160-B (WP 05-WH1722) containers 

documents the WIPP requirements for processing RH 

containers. RH Doc Package BC-ID0015.PDF 

provides an example of the RH receipt and handling 

documentation. 

Satisfactory 

9 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. Container Number ID0015, (Borehole 079) was 

tracked for verification. The Waste Container Data 

Report was generated from the WWIS. Container 

disposal date was 04/24/07 and posted on the 

underground disposal map. The container data report

for ID0015 was generated by WWIS. WP 05-

WH1710, Section 20.45 says to record RH 

emplacement location on underground map. 72-B 

Cask serial number, 72-B Cask shipment numbers 

were verified and concur with WWIS. 

Satisfactory

10 Content of RH canisters 

--pick 1 to 3 canisters 

Borehole 079, container number ID0015, 

Borehole 022, container number ID0028 

Waste Container Data Reports for these were 

generated by WWIS and EPA verified them. 

Satisfactory
26

11 Volume and mass and/or 

concentration of important waste 

components and radionuclides 

(RH and CH)? 

Are they within statutory and 

regulatory limits? 

Waste Container Data Report showing detailed 

description of nuclide information for the container 

numbers – BN10147029 (CH) and ID0028 (RH) were 

generated and verified by the inspectors. 

Yes 

Satisfactory

Question: Procedure 

12 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? 

In the WIPP Waste Handling Operation WWIS User’s 

Manual, WP 05–WH.01, Revision 2, 10/5/06, 

Attachment 1 – special requirements for additional 

MgO are discussed and CH Waste Processing, WP 05-

WH1011 Section 5.0-NOTE, states that the WHE will 

calculate the safety factor (SF) at the end of each shift 

and that the WHM must be notified if the SF is below 

1.67. EPA verified that this process is performed 

(Attachments F). 

Satisfactory

13 Is there documentation that 

identifies how the MgO should be 

placed with high CPR waste? 

Yes. Section 5.2 of WP 05-WH1011 requires that 

additional supersacks are to be placed in the waste

stack if the WHM determines that it is required. 

Satisfactory

# Question: Records/WWIS 

14 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, WWIS Waste Container Data 

Report (for containers ID0015, ID0028, BN10173001) 

contain container number, shipment number, 

emplacement information in the underground. These 

data were verified for waste containers by the 

inspectors. 

Satisfactory

15 Is DOE maintaining records of 

waste shipments and 

emplacement properly? CH, RH 

Yes, WWIS Reports (Waste Container Data Report, 

Emplacement Report, RH Receipt) and underground 

maps verify that records are properly maintained for 

both CH and RH waste containers. 

Satisfactory

16 Do the characterization module, 

certification module, shipping 

module, and inventory module 

adequately record the required 

information? 

Yes. DOE staff queried the WWIS for this 

information and demonstrated (via Waste Container 

Data Reports, and Shipment Summary Reports) that 

they adequately recorded the required information. 

WP 05-WH.01, WP 05-WH1729, WP 08-NT3020 

describe the procedures for recording of data. The

inspectors examined waste containers, ID0015, 

ID0028, BN10173001 documents to verify that this 

information is adequately recorded. 

Satisfactory

17 Characterization Module - 

Review a WWIS Waste Container 

Data Report. Does this report 

adequately record the Waste 

Stream Profile Form information? 

Yes. WWIS staff generated the Waste Container Data

Reports for BN10173001, BN10147029, ID0028, and 

ID0015. These reports contain Waste Stream Profile

information for each container. The inspectors 

verified that this module contains this information. 

Satisfactory
27

18 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

19 Shipping Module - Review the 

Shipment Summary Report. Does 

the report correctly record the 

containers shipped? CH, RH 

Yes. The inspectors examined the Shipment Summary 

Reports for containers CH-BN10173001 and RHID0028 and verified that each report contained the

correct containers. 

Satisfactory

20 Inventory Module - Review the 

Waste Emplacement Report. 

Does this report adequately record 

the date of receipt, and disposal 

locations of containers? CH, RH 

Yes. The Waste Emplacement Report (WER) records 

for RH-ID0015 and RH-ID0028 contain the container 

number, shipment number, emplacement data and 

underground location. The inspectors verified that the 

WER recorded the information adequately. 

Satisfactory

21 Is MgO implementation 

appropriately documented? 

Where is it described? 

Does the WWIS properly track 

MgO emplaced quantity and 

location? 

Where is this described? 

Yes. Procedures WIPP Waste Handling Operations 

WWIS User’s Manual, WP 05-WH.01, Section 6.2.5 

and CH Waste Processing, WP 05-WH1011, Section 

5.0 and Attachment 6 describe and documents the 

process. MgO information is input by the WHE into 

the WWIS computer database in the Emplace 

Containers Underground screen as documented in WP 

05-WH.01, Section 6.1. Processing of released 

shipments, emplacement of processed containers and 

emplacement of MgO on completed stacks are done as 

described in WP 05-WH1011. The inspectors verified 

that MgO emplacement is appropriately implemented 

and tracked properly (see Attachment F). 

Satisfactory

22 Is DOE properly tracking the 

MgO backfill so that the MgO 

safety factor can be accurately 

calculated? 

Yes. As noted in Q-21, above, procedures WP05-

WH.01, Attachment 1 and WP 05-WH1011 show that 

MgO tracking is adequate. The MgO safety factor 

determination is shown in WP 05-WH.01 (Fig. 6-6, 

WWIS MgO Screen, see Attachments E and F) verify 

that MgO is adequately tracked and the safety factor is 

accurately calculated and maintained. 

Satisfactory

23 Is DOE assuring that the 1.67 

safety factor being maintained on 

a room basis? 

What methodology (equations) 

are being used to calculate the 

safety factor? 

Yes. Procedure WP 05-WH1011, Rev.28, CH Waste 

Processing Section 5.0 states that the safety factor of 

1.67 must be maintained. The MgO safety factor 

fluctuates with time. Attachment G shows an example 

of the MgO Safety Factor calculation. The inspector 

verified that DOE maintains a safety factor of 1.67 for 

each room and that the factor is calculated properly, 

Satisfactory
28

24 Does the WWIS accurately 

calculate the 1.67 safety factor 

and recommend the proper 

amount of MgO to emplace? 

Where has this been verified? 

Yes. This is performed on a regular basis. WIPP 

Waste Handling Operations WWIS User’s Manual , 

WP 05-WH.01, Section 6.2.5 and Attachment 1 

describes the steps. During the 2006 annual 

inspection EPA verified that the amount of MgO is 

properly determined and is documented in WWIS. The 

Software Validation Test, MgO Emplacement process 

and Safety Factor Calculation Revision 0, March 2, 

2005 documents the testing of the new modules added

to WWIS to track MgO and calculate the safety factor 

on an ongoing basis room by room. The inspector 

verified that this approach has not changed. 

Satisfactory

25 Is there documentation that 

describes how the site will use 

and implement the MgO module 

of the WWIS? 

Yes. WIPP Waste Handling Operations WWIS User’s 

Manual, WP 05-WH.01, Section 6.2.5 notes that the 

waste handling engineer is to input MgO data into the 

WWIS. The MgO safety factor calculation is done 

routinely as described in WP 05-WH.01, Attachment 

1. The inspector verified this activity (see Attachment 

G). 

Satisfactory
29

Attachment I 

Documents and Records Received During the Inspection 

> COB-E2007-S0 : Containers emplaced - Opening Meeting Slides. 

 -List type of container and quantities emplaced for each site. Copied in Attachment B 

> COB-E2007-S1 : Waste materials emplaced as of 071707 

 - List types and quantities of materials emplaced as of 071707. Copied in Attachment C. 

> COB-E2007-S2 : Waste materials emplaced as pf 071707 – epa2.txt 

 - List types and quantities of materials emplaced as of 071707. Copied in Attachment C. 

> COB-E2007-S3 : MgO analysis 0702-1007 

 - MagChem chemical analysis of purity of MgO shipment number SL9847189. 

> COB-E2007-S4 : WWIS data input screen used to Emplace Container Underground. 

> COB-E2007-S5 : RH Cast Unloading Data sheets, 042307, WP 05-WH1729 

 - Records various steps of RH 72B shipment unloading. 

> COB-E2007-S6 : RH document package for container ID0015RH 

 - Package includes: waste manifest, waste receipt checklist, shipment approval email, shipment 

summary report, waste processing data sheet, waste emplacement report, radiological survey report, and

photo of container ID number. 

> COB-E2007-S7 : RH document package for container ID0028 

 - Package includes: waste manifest, waste receipt checklist, shipment approval email, shipment 

summary report, waste processing data sheet, waste emplacement report, radiological survey report, and

photo of container ID number. 

> COB-E2007-S8 : CH Waste Processing, Technical Procedure WP 05-WH1011, Revision 26, 03/28/07 

– Instruction for processing CH shipments. 

> COB-E2007-S9 : WWIS Shipment Status Display 071207. Copied in Attachment D. 

 - WWIS display screen showing status of shipments being process for each site. 

> COB-E2007-S10 : WWIS Shipment Summary Report of container BN10173001 

 - List waste codes, radionuclide activity, and material weights for each container. 

> COB-E2007-S11: WWIS Waste Emplacement Report for container ID0028 

 - Documents specifics about underground location of waste containers. 

> COB-E2007-S12: WWIS Waste Emplacement Report for container ID0015 

 - Documents specifics about underground location of waste containers. 

> COB-E2007-S13 : WWIS Waste Profile Reference Data

 - List the characteristics of a particular waste stream. 
30

> COB-E2007-S14 : WIPP Waste Handling Operations WWIS User’s Manual, WP 05-WH.01, Revision 

2, 10/5/06 

> COB-E2007-S15 : Waste Container Report for container LASB00184 

 - List details about a specific containers characteristics; such as: generator site waste stream 

types, activities, weights. 

> COB-E2007-S16 : WWIS Shipment Summary Report for container LASB00184 

 - List waste codes, radionuclide activity, and material weights for each container. 

> COB-E2007-S17 WWIS Waste Emplacement Report for container LASB00184 

 - Documents specifics about underground location of waste containers. 

> COB-M2007-W1 : Nuclide Report RPO380 from the WWIS at 1530 on 071207 

 - List the total masses and radionuclide activity for each Panel and Room. 

> COB-M2007-W2 : WWIS Shipment Summary Report for container BN10173001 

 - List waste codes, radionuclide activity, and material weights for each container. 

> COB-M2007-W3 : WWIS Shipment Summary Report for container ID0028 

 - List waste codes, radionuclide activity, and material weights for each container. 

> COB-M2007-W4 : Waste Container Data Report for container BN10147029 

 - List details about a specific containers characteristics; such as: generator site waste stream 

types, activities, weights . 

> COB-M2007-W5 : Waste Container Data Report for container BN10173001 

 - List details about a specific containers characteristics; such as: generator site waste stream 

types, activities, weights. 

> COB-M2007-W6 : Waste Container Data Report for container ID0028 

 - List details about a specific containers characteristics; such as: generator site waste stream 

types, activities, weights. 

> COB-M2007-W7 : Waste Container Data Report for container ID0015 

 - List details about a specific containers characteristics; such as: generator site waste stream 

types, activities, weights.