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 201323 Contents

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

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

3.0 Inspection Team, Obse rvers 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 wi th 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 TR U Mixed Waste Disposal Configuration .............. 9

Figure 3 Arrangement of disposed waste in a room ........................................ 104 Figure 4 Photo of di sposed waste in Panel 6 Room 5....................................... 11

Figure 5 Equipment prepar ed 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................................. 125 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) Wast e 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 tr ansuranic (TRU) waste as defined by the WIPP Land

Withdrawal Act. 1 EPA certified that WIPP complies wi th the Agency’s radioactive waste disposal regulations (Subparts B an d C of 40 CFR Part 191) on May 18, 1998.

The purpose of this annual inspection is to de termine that waste sent to WIPP during the past year has been emplaced in the undergroun d 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 contac t-handled and remote-handled TRU wastes within the repository, the emplacement of magnesium ox ide (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 approp riately tracked and r ecorded, 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 findi ngs or concerns during this inspection.

1 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 ha s 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 perform ed 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 Comp liance Criteria and the certification d ecision 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 th is inspection included: demonstra tion 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) backf ill in amounts to fulfill ce rtification requirements and other approvals, maintenance of relevant waste packaging records, including the electronic Waste Data System (WDS) and the verification of appropriate ly 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 Washingt on TRU-Solutions (WTS) under contract to DOE, and6 the majority of waste related activ ities onsite are describe d 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 a nd Julia Marple of the New Mexico Environment Department observed the in spection activities. A par tial 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 Insp ector 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 Oversight7 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) facilit y, which is located approximately 26 miles south east of Carlsbad, New Mexico. The opening meeti ng with CBFO and WTS personnel was held on the morning of July 17, 2012. Facility staff presented in formation addressing progr am 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 wa s to determine the nature and extent of changes taken place in the areas of emplacement activitie s 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 packag es and MgO that had been emplaced in Panel 6. Inspectors reviewed records documenting that wast e emplacement and MgO tracking were conducted in accordance with procedures. Inspectors selected se veral containers and reco rded their numbers (see Figure 3 for container locations), the records for thes e containers were examin ed both in the repository and later using the WDS computer database, to veri fy correct waste information is recorded by DOE. WTS personnel answered EPA questions about how wast e is handled and emplaced. The inspectors also examined air monitoring locatio ns, 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 buildi ng aboveground. On July 19, inspecto rs accessed the WDS, and were able to generate Container and Canister Data Repor ts for the RH boreholes and CH waste containers observed in the underground. Insp ectors discussed record-keepi ng procedures with WDS data

administrators at the Carlsbad Fi eld Office, and WTS personnel genera ted additional reports and queries8 for the inspectors. EPA presented its preliminary obser vations at a close-out meeting on the afternoon of July 19.

5.0 WASTE EMPLACEMENT/WDS

Wastes received at the repository include contac t-handled (CH) transuranic wastes from Argonne National Laboratory-East (ANL-E) in Illinois, Bett is Atomic Power Laboratory, GE Vallecitos Nuclear Center, Lawrence Livermore National Laboratory, Sa ndia National Laboratory, Los Alamos National Laboratory (LANL), Idaho Nationa l Laboratory (INL), Hanford S ite in Washington, Rocky Flats Environmental Technology Site (RFETS), Savannah Rive r Site (SRS), the Nevada Test Site (NTS), and the Oak Ridge National Laboratory (O RNL) in Tennessee. These wast es 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 supercom pacted waste, Ten Drum Overpacks (TDOP), and Standard large Box (SLB2) containe rs. RH wastes from INL, ORNL, and SRS have been emplaced in the WIPP, using the RH canisters designe d to fit the 72-B shipping container.

The repository is subdivided into panels, each pa nel 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 ar e always placed on the floor of the room, occupying the bottom and middle position of a waste column. SW Bs and drums may be emplaced in any order, with most wastes emplaced as received. The waste colu mns 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).9 Figure 2 Typical RH and CH TRU mixed waste disposal configuration10 Figure 3 Arrangement of Disposed Waste in a Room

Figure 3 illustrates th e arrangement of disposed cont act-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. Th e Horizontal Emplacement/Retrieval Equipment set up to emplace a RH canister is shown in Fi gure 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 inspecto r noted the shipment identification numbers directly off the emplaced containers. The contai ners selected are identif ied in Table B below.

Table B:

Waste Containers Review ed 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 gene rated the Nuclide Report, Materials Emplacement Report11 and the MgO safety factor calculations. A ll electronic records we re 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 emplacement12 Figure 6 Emplaced RH Waste selected for review

Figure 7 SLB2 emplaced 9/13/ 2011 in Panel 6 Room 713 6.0 MAGNESIUM OXIDE BACKFILL

Magnesium oxide (MgO) is the engineered ba rrier used in the repository as backfill, as specified in DOE’s Compliance Certificati on 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 av erage reactivity from th e 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 el ectronically using a WDS bar code reader, or manually via paper forms if a bar code reader is unavailable. The appropriate forms (CH Waste Download ing 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 emplacem ent in Panel 6, Room 5 and that MgO was emplaced on top of the CH waste stacks as stip ulated. At the conclusion of each shift, the WHE must electronically verify the safety fact or 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 rela te 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 c ontainers high toppe d 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-pack s, 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 LIMITS14 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 Ju ly 18, 2012. More detailed data on the total amounts of specific materials emplaced was provided by WDS staff.

EPA establishes limits for certain waste co mponents 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 10 7 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, plas tic and rubber (CPR) materials. In the original CCA, DOE calculated

2.2 x 10 7 kg of CPR, establishing EPA’s limit. In the subsequent performance assessment baseline calculations, DOE added packaging materials to the calculations, and now th e CPR limit for WIPP is

2.4 x 10 7 kg (see Table C). CPR values are tracked on a pe r container basis and the current CPR values as of July 18, 2012 are listed in Table C.

As of this inspection the WIPP c ontained 6,005,600 kg of CPR in waste and 1,644,745 kg of CPR in packaging material. In additi on, 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 ce llulosic, 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 reposito ry 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 Cellulosi c 63,301.83
Plastic 3,210,398.48 Plastic 431,716.00

Rubbe r 350,668.43

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

Packaging CPR: MgO CPR: Type Weight (kg) Type W eight (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)15 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, accordi ng to specified plans documented in the CCA. EPA concludes that DOE’s emplacement activities and r ecords are adequate, and that CPR and MgO are appropriately tracked. EPA identified no findings or concerns with the emplacement portion of the inspection.16 Attachment A



### EPA WIPP Emplacement Insp ection 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: demonstra tion 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 a pplicable 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 in spection, 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 fac ility located twenty-six miles southeast of Carlsbad, New Mexico and the Carlsbad Field O ffice (CBFO) in Carlsbad. Inspection activities will include examination of the underground fac ilities, 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:17 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 Nuclid e Report Through 2012-07-18

Panel Number: 6 Room Number: 3 Radionuclide Activity (Ci) Act. Unce rt (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 INORGA NIC MATERIAL 7,436,612.3118 10 Waste SOLIDIFIED ORGA NIC 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 IN ORGANIC 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: 76,887,574.5619 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’sCompliance 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 verifica tion confirmed adherence to procedure (e.g. TDOPs placed in bottom position of waste columns.) Satisfactory20 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. Satisfactory21 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: Procedures22 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. Satisfactory23 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 Satisfactory24 18 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, 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/WDS25 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 unde rground 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