1

DOCKET NO: A-98-49 

Item: II-B3-125

2012 – Emplacement Inspection Report

EPA INSPECTION No. EPA-WIPP-7.12-17c

OF THE 

WASTE ISOLATION PILOT PLANT 

July 17-19, 2012 

U. S. ENVIRONMENTAL PROTECTION AGENCY 

Office of Radiation and Indoor Air 

Center for Waste Management and Regulation

1200 Pennsylvania Avenue, NW 

Washington, DC 20460

March 2013
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Contents

1.0 Executive Summary........................................................................ 5 

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

3.0 Inspection Team, Observers and Participants........................................... 6 

4.0 Performance of the Inspection............................................................. 7 

5.0 Waste Emplacement/WDS................................................................. 8 

6.0 Magnesium Oxide Backfill................................................................. 13 

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

8.0 Summary of Results.......................................................................... 15 

Attachments

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

Attachment B – Summary of Nuclide report through 2012-07-18............................. 17 

Attachment C – Materials Emplaced in WIPP as of July 18, 2012............................. 17 

Attachment D – Procedures Examined.............................................................. 19 

Attachment E – Inspection Checklist................................................................ 26 

Tables

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

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

Table C Emplaced CPR Quantities as of .................................................... 14

Figures

Figure 1 WIPP Inspection Team................................................................ 7 

Figure 2 Typical RH and CH TRU Mixed Waste Disposal Configuration .............. 9 

Figure 3 Arrangement of disposed waste in a room ........................................ 10 
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Figure 4 Photo of disposed waste in Panel 6 Room 5....................................... 11 

Figure 5 Equipment prepared for RH waste emplacement in ............................ 11 

Figure 6 Emplaced RH Waste selected for review............................................ 12 

 Figure 7 SLB2 emplaced 9/13/ 2011 in Panel 6 Room 7................................. 12 
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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 17 through July 19, 2012, in accordance with 40 CFR 194.21. The WIPP 

is a disposal facility 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 and remote-handled 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 Waste Data System (WDS). 

EPA examined 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 cellulosic, plastic and 

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

properly, and that MgO is emplaced properly. EPA observed the use of the proper waste 

emplacement procedures in the underground and successful implementation of the WDS bar 

code reader. EPA did not identify any findings or concerns during this inspection. 

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

WIPP LWA Amendments, Public Law 104-201. 

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 (EPA Air Docket A-93- 

02, Item II-G-01) and other approvals. EPA performed this inspection under the 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 uses 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 remote-handled (RH) and contact-handled (CH) 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 Waste 

Data System (WDS) 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 
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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 D. 

3.0 INSPECTION TEAM, OBSERVERS, AND PARTICIPANTS

The inspection team consisted of four EPA staff. Thomas Kesterson and Julia Marple of the 

New Mexico Environment Department observed the inspection activities. A partial list of inspection 

participants is provided in Table A. 

Table A 

Inspection Participants

NAME POSITION AFFILIATION 

Tom Peake Inspector EPA ORIA 

Jonathan Walsh Inspector EPA ORIA 

Kathleen Economy Inspector EPA ORIA 

Nick Stone Inspector EPA Region 6 

John Doherty WTS 

John Callicoat RES 

Rick Salness RES 

Jennifer Hendrickson WTS 

Mansour Akbarzadeh WSMS 

Ty Zimmerly WTS 

Ed Lewis WTS 

Terry Batchelder WTS 

Randy Britain WTS 

Steve Wagner SNL 

Rey Carrasco WTS 

Mike Walentine WTS 

David Squires WTS 

Dan Ferguson DOE/CBFO 

John VandeKraats WTS 

Tania Stewart RES Intern 

Tom Klein RES 

Tom Kesterson Observer NMED Oversight 
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Figure 1 

WIPP Inspection Team 

4.0 PERFORMANCE OF THE INSPECTION

The inspection took place from July 17 to July 19, 2012, 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 17, 2012. Facility staff presented information addressing program status, updates and 

changes since the last EPA emplacement inspection which took place from May 10 to May 12, 2011. 

The primary focus of the emplacement inspection was to determine the nature and extent of changes 

taken place in the areas of emplacement activities and documentation since last year’s inspection. 

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

morning of July 18, in order to examine waste packages and MgO that had been emplaced in Panel 6. 

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

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

Figure 3 for container locations), the records for these containers were examined both in the repository 

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

WTS personnel answered EPA questions about how waste is handled and emplaced. The inspectors also 

examined air monitoring locations, and observed the measurement of geotechnical parameters and 

mining in Panel 7. 

During the afternoon of July 18, EPA inspectors observed operations in the CH and RH bay 

areas of the waste handling building aboveground. On July 19, inspectors accessed the WDS, and were 

able to generate Container and Canister Data Reports for the RH boreholes and CH waste containers 

observed in the underground. Inspectors discussed record-keeping procedures with WDS data 

administrators at the Carlsbad Field Office, and WTS personnel generated additional reports and queries 
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for the inspectors. EPA presented its preliminary observations at a close-out meeting on the afternoon of 

July 19. 

5.0 WASTE EMPLACEMENT/WDS

Wastes received at the repository include contact-handled (CH) transuranic wastes from Argonne 

National Laboratory-East (ANL-E) in Illinois, Bettis Atomic Power Laboratory, GE Vallecitos Nuclear 

Center, Lawrence Livermore National Laboratory, Sandia National Laboratory, Los Alamos National 

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

Environmental Technology Site (RFETS), Savannah River Site (SRS), the Nevada Test Site (NTS), 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, Ten Drum Overpacks (TDOP), and 

Standard large Box (SLB2) containers. RH wastes from INL, ORNL, and SRS have been emplaced in 

the WIPP, using the RH canisters designed to fit the 72-B shipping container. 

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 6, Room 5 and RH waste in the walls of Panel 6, 

Rooms 4 and 3. 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 may be emplaced in any 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 3). RH 

waste is placed in the walls on eight foot centers (Figures 2, 5, and 6).
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Figure 2

Typical RH and CH TRU mixed waste disposal configuration
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Figure 3 

Arrangement of Disposed Waste in a Room

Figure 3 illustrates the arrangement of disposed contact-handled waste in underground. 

Represented are stacks of seven-packs of drums and standard waste boxes. Figure 4 shows the 

waste face in Panel 6 Room 5. The waste face shows three packs of 100 Gal drums, standard 

waste boxes, and a seven pack of 55 Gal drums. In Panel 6, Room 4 inspectors observed 

boreholes drilled to emplace RH containers. The Horizontal Emplacement/Retrieval Equipment 

set up to emplace a RH canister is shown in Figure 5. Figure 6 shows one of the RH waste 

boreholes selected for records review. Figure 7 shows emplacement of a SLB2 waste container. 

Emplaced September 13, 2011, in Panel 6 Room 7, the SLB2 is the newest container approved 

for WIPP designed for oversized material. 

While underground in Panel 6, Room 5, EPA inspectors selected recently emplaced 

CH waste packages for review. The inspector noted the shipment identification numbers 

directly off the emplaced containers. The containers selected are identified in Table B below. 

Table B: 

Waste Containers Reviewed During Inspection

CH Waste Containers 

Reviewed During Inspection 

(Panel 6, Room 5)

Container Number Container Type

BN10444908 100 Gal Drum 

BN10444911 100 Gal Drum 

LASB01678 Standard Waste Box (SWB) 

 SR51782101 Standard Waste Box (SWB) 

SRSB01261 Standard Waste Box (SWB) 

RH Waste in Selected

Boreholes (Panel 6, Room 4)

Container Number Borehole

AE0126 095 

BC0127 097 

On the morning of July 19 at CBFO, inspectors met with WTS personnel, who 

answered questions and generated the Nuclide Report, Materials Emplacement Report 
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and the MgO safety factor calculations. All electronic records were found to contain 

required waste stream, container, and emplacement information. 

Figure 4

Emplaced waste in Panel 6, Room 5 

Figure 5

Equipment prepared for RH waste emplacement 
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Figure 6

Emplaced RH Waste selected for review 

Figure 7

SLB2 emplaced 9/13/ 2011 in Panel 6 Room 7
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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 (excess 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 stipulate that DOE must ensure a minimum 

reactivity of 96% for the MgO emplaced, and maintain the safety factor on a roomby-room basis. DOE instituted this change in March 2009, and it was a focus of EPA’s 2009 

inspection. 

During the opening meeting, Terry Batchelder and Randy Britain gave a presentation 

on DOE’s MgO program and management. They noted that the only significant change in 

MgO emplacement was the introduction of 3000 lb super sacks. DOE maintains a safety 

factor of 1.2 on a room by room basis. The average reactivity from the supplier measured for 

October 24, 2011 through June 12, 2012, was 97.65. At the last inspection May of 2011 the 

average reactivity was also 97.65. 

Process steps guiding MgO placement and documentation in the underground 

continue to be found in WP 05-WH1025, CH Waste Downloading and Emplacement, and 

WP-05-WH.02, WIPP Waste Handling Operations WDS User’s Manual. Waste Handling 

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

WDS 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 Attachments 1 and 3 of WP 

05-WH1025. While in the underground repository, EPA inspectors verified that the proper 

procedures were used to track MgO emplacement in Panel 6, Room 5 and that MgO was 

emplaced on top of the CH waste stacks as stipulated. At the conclusion of each shift, the 

WHE must electronically verify the safety factor of 1.2 using the WDS. MgO safety factor 

calculations made using the WDS allowed inspectors to verify that the MgO safety factor was 

maintained in Panel 6, Room 5. 

Checklist items 12-17 and 24 specifically relate to MgO management and demonstrate 

that DOE has appropriate processes in place to ensure that MgO is properly emplaced. 

DOE is emplacing waste stacked 2-3 containers high topped with 3000 lb MgO 

Supersacks. Figure 4 shows the container types visible during the inspection. Visible on the 

waste face are black 100-gallon drums in 3-packs, smaller white containers are standard 

waste boxes, and white 55-gallon drums in 7-packs. 3000 lb MgO supersacks are visible on 

top of the waste columns. 

7.0 COMPARISON WITH INVENTORY LIMITS
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The Nuclide Report and the Emplaced Materials Report provided data for emplaced waste, 

including total activities of the ten EPA-tracked radionuclides, total weights of ferrous and non-ferrous 

metals, and the CPR/MgO balance by room, as of July 18, 2012. More detailed data on the total amounts 

of specific materials emplaced was provided by WDS staff. 

EPA establishes limits for certain waste components at WIPP by approving performance 

assessment inventory estimates. The limit for ferrous metals is a minimum limit. The amount of iron 

and steel is now at 24,874,327 kg. The minimum limit of 2 x 107 kg iron was met for the repository in 

2011. 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 calculated 

2.2 x 107 kg of CPR, establishing EPA’s limit. 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 18, 2012 are listed in Table C. 

As of this inspection the WIPP contained 6,005,600 kg of CPR in waste and 

1,644,745 kg of CPR in packaging material. In addition, emplacement CPR, such as the slip sheets 

used to aid the emplacement of the containers, accounts for another 495,716 kg of CPR. This is a 

total of 8,269,939 kg of cellulosic, plastic and rubber material. The mass of rubber materials currently 

accounts for approximately 4.2% of the total mass of CPR, compared to 4.7% in 2011, 4.3% in 2010, 

3.4% in 2009, 5% in 2008, 4.7% in 2007, and 7% in 2006. The WIPP currently contains approximately 

34% of its maximum limit for CPR. The repository held 30% in 2011, 29% in 2009, 24% in 2008, and 

21% in 2007. 

Table C: Emplaced CPR Quantities as of July 18, 2012

Waste CPR:

Type Weight (kg) 

Emplacement CPR:

Type Weight (kg) 

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

Cellulosic 2,444,534.04 Cellulosic 63,301.83 

Plastic 3,210,398.48 Plastic 431,716.00 

Rubber 350,668.43 

Total 6,005,600.95 (kg) 495,017.83 (kg) 

Packaging CPR: MgO CPR:

Type Weight (kg) Type Weight (kg) 

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

Cellulosic 881,512.62 Cellulosic 59,464.20 

Plastic 763,232.16 Plastic 65,111.70

Total 1,644,744.78 (kg) 124,575.90 (kg) 

Grand Totals:

Cellulosic + Plastic = 7,919,271.03 

Rubber = 350,668.43 

Total CPR = 8,269,939.46 (kg)
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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, and that CPR and MgO are 

appropriately tracked. EPA identified no findings or concerns with the emplacement portion of the 

inspection. 

 
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Attachment A 

EPA WIPP Emplacement Inspection Plan for the year 2012 

Purpose: 

The purpose of this inspection is to verify 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 (EPA Air Docket A-93-02, Item II-G-01) and other approvals. 

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 Data System (WDS) 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: 

The inspection will address that changes have taken place to emplacement activities and 

documentation since last year’s inspection. In particular, EPA will review the implementation 

of new procedures which alter the emplacement scheme for MgO while maintaining the safety 

factor of 1.2. This will involve reviewing the applicable procedure, reviewing methods used to 

maintain MgO reactivity, observing the active waste face in Panel 6, interviewing waste 

handling personnel, and reviewing calculations in the WDS. 

EPA will additionally use the underground portion of the inspection to view developments and 

changes that have occurred since the last inspection, including field testing of emplaced 

crushed salt, explosion walls in Panel 5, and mining for the proposed SDDI experiments. In 

conjunction with the Subpart A Inspection, EPA also requests that DOE provide a review of 

VOC monitoring and management activities currently taking place in the underground. 

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, records related to waste emplacement, 

and other information as needed. 

Duration: 

The EPA expects to complete its inspection in three days. 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 

Dates: July 17-19, 2012 

Documents for Review: 
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EPA has received and is reviewing relevant documentation and procedures related to CH and 

RH waste handling and emplacement, MgO emplacement and tracking, and record keeping 

using the WDS. will request additional documentation if needed. 

Information Requested: 

EPA has received and is reviewing relevant documentation and procedures related to Subpart A, 

and will request additional documentation if needed.

Attachment B

Summary Totals WDS Nuclide Report Through 2012-07-18 

Panel Number: 6 Room Number: 3 

Radionuclide Activity (Ci) Act. Uncert (Ci) Mass (g) Mass Uncert (g) 

PU-242 - PLUTONIUM 242 4.576E-4 2.524E-4 1.1526E-1 6.3577E-2 

SR-90 - STRONTIUM 90 8.559E0 2.678E0 6.2022E-2 1.9406E-2 

U-233 - URANIUM 233 3.945E-8 3.184E-8 4.042E-6 3.2623E-6 

U-234 - URANIUM 234 9.864E-4 5.865E-4 1.5608E-1 9.2801E-2 

U-235 - URANIUM 235 3.022E-5 1.938E-5 1.3799E1 8.8493E0 

U-238 - URANIUM 238 3.527E-5 1.762E-5 1.0374E2 5.1824E1 

Y-90 - YTTRIUM-90 8.559E0 2.678E0 1.5733E-5 4.9228E-6 

Totals: 5.4809E1 1.9467E1 1.2349E2 6.5127E1 

Grand Totals Panel 6: 2.2112E6 4.1104E5 5.5537E7 2.3951E7

Attachment C

Materials Emplaced in WIPP as of July 18, 2012 

Hand 

Code MP Material Type Material Description 

Material

Weight

(kg)

P

CH 1 Waste IRON BASE METAL ALLOYS 9,571,973.85

2 Waste ALUMINUM BASE METAL/ALLOYS 51,327.73

3 Waste OTHER METAL/ALLOYS 335,520.45

4 Waste OTHER INORGANIC MATERIALS 1,701,852.43

6 Waste CELLULOSICS 2,444,259.42

7 Waste RUBBER 350,661.13

8 Waste PLASTICS 3,150,687.26

9 Waste SOLIDIFIED INORGANIC MATERIAL 7,436,612.31
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10 Waste SOLIDIFIED ORGANIC MATERIAL 2,521,122.15

12 Waste SOILS 635,079.50

13 Steel Packaging STEEL CONTAINER MATERIALS 14,777,941.16

14 Plastic Packaging 

PLASTIC/LINERS CONTAINER 

MATERIALS 762,828.30 7

15 

Cellulosic 

Packaging CELLULOSICS PACKAGING MATERIALS 881,508.36 8

18 Emplacement CELLULOSIC EMPLACEMENT MATERIAL 63,301.83

20 Emplacement PLASTIC EMPLACEMENT MATERIAL 431,716.00

21 Steel Liners STEEL LINER MATERIALS 81.30

99 

Emplaced 

Dunnage STEEL DUNNAGE CONTAINERS 161,213.70

RH 1 Waste IRON BASE METAL ALLOYS 63,901.95

2 Waste ALUMINUM BASE METAL/ALLOYS 29.20

3 Waste OTHER METAL/ALLOYS 9.72

4 Waste OTHER INORGANIC MATERIALS 13.06

6 Waste CELLULOSICS 274.62

7 Waste RUBBER 7.30

8 Waste PLASTICS 59,711.22

9 Waste SOLIDIFIED INORGANIC MATERIAL 194.67

10 Waste SOLIDIFIED ORGANIC MATERIAL 15.06

13 Steel Packaging STEEL CONTAINER MATERIALS 299,215.46

14 Plastic Packaging 

PLASTIC/LINERS CONTAINER 

MATERIALS 403.86

15 

Cellulosic 

Packaging CELLULOSICS PACKAGING MATERIALS 4.26

MgO 16 Emplacement MAGNESIUM OXIDE 31,061,531.40

18 Emplacement CELLULOSIC EMPLACEMENT MATERIAL 59,464.20

20 Emplacement PLASTIC EMPLACEMENT MATERIAL 65,111.70

Totals: 76,887,574.56

 
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Attachment D 

EPA Emplacement Inspection Checklist – July 17-19, 2012 

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, CH Waste 

Downloading and Emplacement, Section 2, describes 

the CH emplacement procedures. Visual verification 

of the emplaced waste 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
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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, 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 6, Room 5, Rows 107 - 109) 

- 100 Gal Drum, BN10444908 

- 100 Gal Drum, BN10444911 

- Standard Waste Box (SWB) – Overpack LASB01678

- Standard Waste Box (SWB) SR51782101 

- Standard Waste Box (SWB) – Overpack SRSB01261

RH Waste (Panel 6, Room 4) 

- Borehole 095, AE 0126 (RH CANISTER WITH 

REMOVABLE LID-OVERPACK – 3, 55 gallon 

drums) 

RH Waste (Panel 6, Room 4) 

- Borehole 097, AE 0127 (RH CANISTER WITH 

REMOVABLE LID-OVERPACK – 3, 55 gallon 

drums)

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. 3000-pound supersacks were observed to be 

emplaced on top of each waste assembly at the active 

waste face in Panel 6 Room 4, Rows 107-109. 

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. Site operators 

demonstrated the use of the WDS bar code reader to 

track emplacement of waste and MgO. 

Documentation was determined to be adequate.

Satisfactory
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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, 72-B RH Processing, and WP 05- 

WH1725, RH Waste Downloading and Emplacement.

Satisfactory.

7 Are RH containers appropriately 

tracked? 

Where is the information? 

--In the WDS, what report 

--During the receipt/transfer 

process where is it recorded? 

--In the underground?

Yes. Appropriate information is found in the WDS 

Canister Data Report, 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. The Canister Data Report was 

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 and Canister 

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, 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?

No. The canister ID number is verified by two 

operators during cask transfer, via closed-circuit 

television in accordance with procedure 05-WH1710, 

72-B RH Processing, Section 8.24. Tapes are 

maintained for one year, and WP 

05-WH1710 Att. 1, RH Waste Processing Data Sheet, 

then becomes the permanent record. EPA finds this to 

be adequate.

Satisfactory

Question: Procedures 
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12 Do DOE procedures reflect an 

MgO safety factor to 1.2? 

Yes. 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 WDS User’s Manual, WP-05-WH.02, Sections 

6.2.5, 9.5.3, and Attachment 1 reflect the 1.2 safety 

factor and the use of 3,000-lb. supersacks as 

necessary. WHEs were observed to be using current 

procedures and the WDS bar code reader to record 

MgO emplacement in the underground. 

Satisfactory 

13 Are both CPR and MgO 

calculated and tracked on a 

room- by-room basis? 

Yes. Calculations are performed by the Waste 

Handling Engineer at the conclusion of each shift, 

through the WDS, using the 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, and WP 05-WH1105, MgO Sample Records 

Management, set forth analytical and document 

management procedures to verifying that each 

shipment of MgO maintains a 96 +/- 2% reactivity. 

Average reactivity from the Supplier October 24, 

2011 – June 12, 2012 was 97.65 

Satisfactory 

15 Is the acceptance of the MgO 

backfill material from the 

supplier documented? 

Yes. WP 05-WH1105, MgO Sample Records 

Management, 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? 

Yes. General procedures are found in the WIPP 

Waste Handling Operation WDS User’s Manual, WP 

05–WH.02, Attachment 1, Special Requirements for 

Additional MgO. Section 3 of WP 05-WH1025 calls 

for notification of the WHM if daily reports show the 

MgO safety factor of a room to be less than 1.2. 

Satisfactory 
23

17 Is there documentation that 

identifies how MgO should be 

placed with high CPR waste? Yes. WP 05-WH1025, CH Waste Downloading and 

Emplacement, Attachment 3, Supersack/BRT 

Emplacement Data Sheet; and WP 05-WH1058, CH 

Waste Handling Abnormal Operations, Sec. 4.0, BRT 

Emplacement 

Satisfactory 
24

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, 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/WDS 
25

 Do the characterization module, 

certification module, shipping 

module, and inventory module 

adequately record required 

information? 

Reports available through the EPA Dashboard 

contain the container number, shipment number, 

emplacement data and underground location. EPA 

staff queried the WDS to verify that this information 

is recorded correctly. 

Satisfactory 

19 Does the WDS adequately 

document waste shipment and 

emplacements information for 

waste containers selected? (Item 

3 above) CH, RH 

Yes. Canister, Overpack, and Container Data Reports 

were retrieved, all of which correctly reflected 

container number, shipment number, and 

emplacement information in the underground. 

Satisfactory 

20 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 Container Data Report. Dose limits for each of the 

containers examined by EPA inspectors (listed in 

Item 3) were below statutory limits. 

Satisfactory 

21 Review a Waste Container Data 

Report. Does this report 

adequately record the Waste 

Stream Profile Form 

information? 

Yes. For all containers inspected, inspectors found 

Container and Canister Data Reports to contain Waste 

Stream IDs, as well as all necessary radiological and 

chemical profile information. 

Satisfactory 

22 Review the Shipment Summary 

Report. Does the report correctly 

record the containers shipped? 

CH, RH 

By querying the Shipment number, the Shipment 

Data report may be generated. Inspectors verified that 

the 

report reflects the containers shipped. 

Satisfactory 

23 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 

24 Is DOE assuring that the 1.2 

safety factor being maintained on 

a room basis? 

Does the WDS accurately 

calculate the safety factor and 

recommend the proper amount of 

MgO to emplace? 

Yes. See questions 12-17. 

EPA inspectors reviewed InSEI Matrix Requirements 

WWIS2-REQ-2126 and -2127 to verify that the WDS 

software calculates MgO excess appropriately. 

 
26

Attachment E 

Procedures Examined