DOCKET NO: A-98-49 

Item: II-B3-102 

2007 - Subpart A Inspection Report 

INSPECTION No. EPA-WIPP-7.07-10a 

OF THE 

WASTE ISOLATION PILOT PLANT 

July 10 to July 12, 2007 

U. S. ENVIRONMENTAL PROTECTION AGENCY 

Office of Radiation and Indoor Air 

Center for Federal Regulation 

1200 Pennsylvania Avenue, NW

Washington, DC 20460 

August 2007
 Table of Contents 

1.0 Executive Summary .................................................................................................................. 1 

2.0 Scope......................................................................................................................................... 1 

3.0 Inspection Team, Observers, and Participants .......................................................................... 1 

4.0 Performance of the Inspection .................................................................................................. 2 

 

5.0 Summary of Findings................................................................................................................ 6 

Attachments

Attachment A Inspection Plan and Checklist 

 

Attachment B Documents Reviewed 

 
1

1.0 Executive Summary

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

Department of Energy (DOE) Waste Isolation Pilot Plant (WIPP) July 10 to July 12, 2007 as part 

of our continued oversight program. This inspection was conducted under the authority of 40 

CFR 191, Subpart A. The purpose of this inspection was to verify that DOE was in continued 

compliance with the dose release standard found at 40 CFR 191.03, Subpart A. 

 EPA reviewed DOE’s ability to monitor radiation releases to the public due to normal 

waste disposal operations and any unplanned or accidental releases that might occur during 

disposal operations. EPA reviewed DOE’s activities related to underground continuous air 

monitors (CAM) false alarms examined during the last inspection. This year EPA reexamined 

DOE’s continued moisture problems and salt loading at the Station A sampling location in the air 

exhaust shaft. In particular, inspectors evaluated DOE’s progress on comments made during the 

2006 inspection. EPA inspectors examined WIPP’s emission control devices and methods used 

to estimate radiation doses to the public. In addition, EPA inspected radiation sample locations 

and equipment, sample processing, and reviewed the computational methods used to estimate 

dose. 

 EPA found that DOE continued to improve its air monitoring program during the past 

year, and responded aggressively and appropriately to Station A issues. Moisture and salt 

loading continues to challenge the Station A sampling location. EPA verified that DOE 

increased probe cleaning frequency as needed and continued to work toward a solution to this 

persistent problem. DOE continues to have an effective radiation sampling program because of 

the diligence of site staff, and can calculate both yearly and accidental dose estimates adequately. 

EPA had no findings or concerns during this inspection. 

2.0 Inspection Scope

 The scope of this inspection was to verify that WIPP continues to effectively capture, 

measure, and calculate radiation doses to members of the public during waste disposal 

operations. Inspection activities included an examination of monitoring and sampling 

equipment. This inspection was conducted under the authority of 40 CFR 191, Subpart A. 

 During this inspection, the Agency selected for specific review the impact of moisture 

and salt loading on the sampling location at Station A and the progress of work on underground 

CAM false alarms. 

3.0 Inspection Team, Observers, and Participants

 The inspection team consisted of three EPA staff. Two members of the New Mexico 

Environmental Department observed the inspection, Thomas Kesterson and Dean Foster. Jerry 

Fox of Pecos Management Services also observed the inspection activities. 
2

Inspection Team Member Position Affiliation

Chuck Byrum Inspection Leader EPA 

Shankar Ghose Inspector EPA 

Tom Peake Inspector EPA 

 Numerous DOE staff and contractors participated in the inspection; below is a partial list. 

Participant or Observer Affiliation

Mike Oliver DOE/CBFO 

Joel Siegel WRES 

Randy Elmore WTS 

Mansour Akbarzadeh WTS 

Linda Frank-Supka WTS 

Dave Kump WTS 

Ed Flynn WTS 

John VandeKraats WTS 

Art Chavez WRES 

4.0 Performance of the Inspection 

The inspection began on Tuesday, July 10, 2007 with an opening meeting that included 

presentations on changes in air monitoring and WIPP laboratory activities (COB-M2007-I4c and 

-I4d). DOE discussed changes in the program since the last EPA inspection in June 2006. This 

discussion included the following changes to the program at WIPP during the past year: 

- Upgraded Station A flow control and differential pressure equipment, 

- First receipt of RH waste, January 28, 2007; added RH waste isotopics to sampling program, 

- Procedures for both effluent monitoring and laboratory analysis have had minor changes, 

- Changes related to the underground CAMs, and 

- Developing processes to analyses Station A shrouded probes to determine the amount of 

loading and techniques to predict when a probe may have salt build-up that require cleaning. 
3

 The EPA inspector observed various activities to verify effective implementation of 

DOE/WTS procedures. EPA reviewed procedures and implementation of procedures; 

interviewed site staff about the steps involved in the changes in underground CAMs, such as new 

sample heads, to mitigate High-High fault events; observed filter changes; and underground 

CAM sampling locations at the air exhaust of Panel 4. 

4.1 Overall Inspection Activities 

 The inspector observed sampling filter changes at Stations A, examined photographs of 

the monthly shrouded probe changes, (see Figure 1 

(COB-A2007-S10 to -S20)), and reviewed 

underground CAM locations. 

 4.2 CAM Alarms Focused on in 2005 and 2006 

As noted in last years inspection, EPA 

closely examined the underground CAM air 

samplers’ persistent High-High alarms during the 

2005 and 2006 inspections. The CAM would 

periodically produce a false alarm and cause the air 

handling system to go into HEPA filter mode. DOE 

determined that the cause of these alarms “...were 

the result of water condensation on the detector face. 

This caused electronic noise resulting in the High-High alarms (COB-A2007-S7).” In response 

to these problems DOE initiated the following changes: reduced underground ventilation in the 

panel are during backshifts, started daily cleaning of detectors using air compressors to minimize 

salt buildup, and tested new detectors, selecting the Canberra Model CAM490 AB and replaced 

all heads as of January 2006 (COB-A2007-S7). Since DOE initiated these changes, the Eberline 

Alpha-6 CAMs have not had a false High-High alarm. EPA believes that DOE/WTS has 

adequately responded to this problem. 

4.3 RADOS CAMs Located at the Air Exhaust of Panel 4 

 DOE has installed two RADOS RAM3CAMs using Shrouded Probes (Figure 2) in the air 

exhaust of Panel 4 and will be using these in future panels. One main advantage of these CAMs 

is that they sense pressure changes across the sample filter, and when a flow decrease is 

registered the filter is automatically changed to a new clean filter – this significantly decreases 

the impact of clogged filters on sampling. These RADOS CAMs are more sensitive and are 

connected to the real-time monitoring system. DOE has had a few problems with false alarms 

during the equipment shake-down process but these new CAMs appear to be a significant 

improvement over previous equipment. 

Figure 1 Probe as Found November 15, 2006
4

Figure 2 – Panel 4 Air Exhaust Shrouded Probes, Auto-Filter Changer, RADOS Spectra Display

EPA believes that the underground samplers at Station D and the CAMs in the air 

exhaust to the operating panels augment the primary sampler at Station A. Therefore, EPA 

continues to monitor the effectiveness of underground sampling locations. 

4.4 Continued Moisture Problems at Station A 

During the fall and winter season DOE continues to have persistent moisture related salt 

buildup at the station of record for compliance with 40 CFR 191, Subpart A – Station A. This 

problem may negatively impact DOE’s ability to acquire representative samples at this location. 

Even though studies have been done in the past that showed that the shrouded probe is ideal for 

application at Station A and out performs other sampling methods, some studies have shown that 

performance efficiency can be impaired by excessive salt loading (COB-A2006-ZE, COBA2006-ZB, and COB-A2006-ZA). 

 As noted in 2006 in EPA’s inspection report the document, Effects of Salt Loading and 

Flow Blockage on the WIPP Shrouded Probe by Chandra, Ortiz, and McFarland (COB-A2006-

ZB), shows the most critical performance measure for the shrouded probe is the inlet effective 

diameter. Decreasing the inlet diameter by salt loading can decrease effluent particulate flow 

into the sampling system. The waistline space, the space between the shroud and the probe 

(Figure 1), is of much less importance in determining the shrouded probe performance. DOE has 

been using the criteria of one-third occlusion of the waistline space and two-thirds occlusion of 

the probe inlet to determine if a probe is operating effectively (COB-A2006-V, Section 8.3). 

In 2006 DOE/WTS and EPA had extensive discussions during inspection interviews to 

attempt to determine the overall effectiveness of effluent sampling at Station A. Ultimately, 

EPA determined that it was not totally clear that Station A was able to acquire adequate samples 

during periods of significant salt loading (Figure 1, you can see salt loading in the waistline and 

on the probe inlet). DOE committed to: 

- ensure that sampling at Station A will be representative of the air flow from the underground 

 by increasing the frequency of preventive maintenance. 
5

- re-evaluation of the shrouded probe acceptance criteria. 

- development of a probe inlet measurement technique to be used for acceptance determinations. 

- evaluation of Station D for additional sampling points (longer term), as well as further 

 consideration of alternatives to Station A. 

 During our 2007 inspection EPA reviewed DOE’s progress related to the commitments 

made in 2006. DOE has continued to increase probe changes and cleaning as necessary and have 

attacked two important areas – attempting to predict when a probe may be loaded with salt and 

needs to be changed based on meteorological data and attempted to develop a more precise 

method to measure the occlusion of the shrouded probe inlet by salt loading. 

Predicting Probe Changes - Site staff 

analyzed historical meteorological data (Figure 3) 

to determine if they can see a relationship 

between measured data and salt loading on the 

shrouded probe (COB-A2007-S32 to -S35). 

They have seen that temperature and humidity 

data can indicate conditions that are right for salt 

loading to develop on the probe. They have 

determined that when the moisture loading in 

intake air into the mine is above 6 gm/kg the 

probe needs to be changed and cleaned weekly or 

twice monthly if the moisture loading is above 5 

gm/kg. DOE is presently testing this approach to see if it is applicable during actual site 

operations (COB-A2007-S36). 

Developing Criteria For Probe Inlet Salt-Loading – The site is also developing a 

photographic technique to measure the amount of 

occlusion of the inlet to the shrouded probe due 

to salt-loading. As shown in Figure 4 DOE is 

testing the concept of comparing a salt-loaded 

probe (the photograph shows a clean sample 

probe) with a standard target (the metal plate on 

the right of the sample probe in the photograph). 

To compare the target to the actual probe they are 

developing a pixel counting technique using the 

SCION Image computer code available from the 

National Institutes of Health (NIH) 

(http://rsb.info.nih.gov/nih-image/about.html). 

This computer code is used to count the number of pixels recorded on a photograph in a selected 

area; therefore by using this method DOE may be able to compare the standard inlet target to the 

salt-loaded probe inlet and calculate the amount of probe inlet occlusion due to salt loading. 

Figure 4 Sample Probe and Inlet Target

Figure 3 Meteorological Data Screen 
6

DOE is also testing this technique to see if it can be used during site operations. 

 EPA believes that DOE commitments and enhanced activities to increased probe changes 

and cleanings, working to improve probe acceptance criteria, and efforts to find ways to possibly 

predict when probes may have salt-loading and attempting to actually measure inlet occlusion 

will ensure that Station A will continue to fulfill the requirements of 40 CFR 191, Subpart A. 

4.5 Other Inspection Activities 

 EPA observed filter changes at 

Stations A (Figure 5) to verify appropriate 

implementation of site procedures. The 

EPA inspector also examined the 

underground CAM locations. EPA found 

all activities consistent with established 

procedures. 

5.0 Summary of Findings

 EPA concludes that DOE 

adequately implements a radiological monitoring and sampling program for WIPP disposal 

operations and appropriately performs calculations to estimate potential releases to the public. 

EPA had no findings or concerns. 

Figure 5 Station A Filter Change
7

Attachment A: Inspection Plan and Checklist 

2007 Subpart A Inspection Plan

Purpose: 

EPA will verify that the Department of Energy (DOE) has been monitoring and calculating 

possible radiation doses to members of the public, due to normal operations and any accidental 

releases, which may have occurred during the last reporting period. This inspection is part of 

EPA’s continued oversight to ensure that WIPP can, during the operational phase of management 

and storage of radioactive waste, comply with the limits expressed in Section 191.03. This 

inspection is conducted under the authority of 40 CFR 191, Subpart A. 

Scope: 

Inspection activities will include an examination of the description of monitoring and sampling 

equipment both on and off site, and in the underground. 

A particular focus of this inspection will be the continued challenges of moisture and salt builtup on the shrouded probes at Station A and its potential impact on the quality and adequacy of 

samples collected at Station A. 

EPA inspectors also wish to begin an in-depth evaluation of the Subpart A sampling 

requirements for the handling and disposal of RH waste at the WIPP site 

Location: 

This inspection will be held at the WIPP facility located twenty-six miles south east of Carlsbad, 

New Mexico and the surrounding vicinity as needed. 

Duration: 

EPA expects to complete its inspection in three days. Each day will begin with an opening 

meeting at 8:00 a.m. and end at 5:00 p.m. with a closeout session. 

Expected Dates: Week of July 9, 2007. 

Documents Required for Review: 

DOE must provide the most recent annual Safety Analysis Report, information that describes 

how measurements are taken, and complete documentation that shows how compliance 

calculations are performed with an explanation of all input parameters and their derivation and 

all related to Subpart A requirements (such as current versions of Letter Report by CTAC, 

Subject: WIPP Air Monitoring Status Second Quarter 2007, 07/11/05, by Susan McCauslin; and, 

Radiological Material Control, Technical Procedure, WP 12-HP3200, Revision 8, 04/28/05). If 

there are any questions as to the documents required, please contact Chuck Byrum at 214-665-

7555. 
8

# CHECKLIST QUESTION June 2007 40 CFR 191.03 Subpart A

Sat. = Satisfactory NA = Not Applicable 

40 CFR 191.03 Compliance Standard EPA Citation Comment (Objective Evidence) Result 

Does DOE “...provide reasonable assurance that 

the combined annual dose equivalent to any 

member of the public in the general environment 

resulting from: (1) Discharges of radioactive 

material and direct radiation from such 

management and storage and (2) all operations 

covered by Part 190; shall not exceed 25 millirems 

to the whole body, 75 millirems to the thyroid, and

25 millirems to any other critical organ.” 40 CFR 

191.03(a) 

40 CFR 191.03 

Subpart A - 

Environmental 

Standards for 

Management 

and Storage 

DOE has demonstrated that they can 

capture, measure, and calculate releases 

to assure that they are and remain 

below these limits. 

Sat. 

Scope of activities considered in 

determining compliance

1 Does DOE demonstrate that all activities at 

the WIPP up until the point of disposal are 

considered in determining compliance? 

EPA 402-R97-001 

Section 2.3, 

Page 4 

The Annual Site Environmental Report 

(DOE-WIPP 06-2225:COB-A2007-A) 

Executive Summary documents the results 

of DOE’s efforts to consider all activities 

that impact compliance. 

Sat. 

2 Does DOE demonstrate that radiation doses 

to the public due to 

 1) actual normal operation and 

 2) any unplanned or accidental releases 

are examined? 

EPA 402-R97-001 

Section 2.3, 

Page 5 

Section 3.0 of the Implementation Plan for 

Subpart A (DOE/WIPP 00-3121: COB-A2006-

A), documents the plan to show how this 

requirement is examined. QAPP for Sampling 

Emissions (WP 12-RC.01:COB-A2006-F), 

documents the QA requirements for the sampling 

of emissions. Annual NESHAP report (COBA2007-AC) demonstrates that normal operations 

are examined. CH Waste Documented Safety 

Analysis (DOE/WIPP 95-2065:COB-A2007-C1) 

and RH Waste DSA (DOE/WIPP 06-3174:COBA2007-C2) documents DOE’s review of potential 

accidents at WIPP. Procedure Emergency 

Radiological Control Response (WP 12-

HP4000:COB-A2006-J) documents radiological 

emergency response activities. 

Sat. 

Media considered in determining compliance

3 Does DOE demonstrate that the air pathway 

is the credible release pathway? 

EPA 402-R97-001 

Section 2.4, 

Page 5 

DOE/WIPP 06-2225 Section 2.2.15 and 

DOE/WIPP 00-3121 Section 2.1 documents 

that the air pathway is the only credible 

release pathway. 

Sat. 

4 Does DOE demonstrate that other exposure 

mechanisms from an air release could include 

inhalation of contaminated air, immersion in a 

plume of radioactive particles, ingestion of soil on 

which contaminated particles have been deposited, 

swimming in ponds in which radionuclides have 

been deposited are considered? 

EPA 402-R97-001 

Section 2.4, 

Page 5 

Sections 2.1 and 3.5 of Implementation Plan 

for Subpart A (DOE/WIPP 00-3121) 

documents the detailed plan for measuring 

these potential exposure mechanisms. 

Annual NESHAP report (COB-A2007-AC) 

demonstrates that these exposure 

mechanisms are included. 

Sat. 
9

# CHECKLIST QUESTION June 2007 40 CFR 191.03 Subpart A

Media considered in determining compliance EPA Citation Comments (Objective Evidence) Result

5 Is DOE monitoring the expected air 

exhaust pathway and performing 

environmental monitoring of other release 

points and exposure pathways to confirm 

air exhaust as the only release pathway? 

EPA 402-R-97-001 

Section 2.4, Page 5

and page 6. 

Section 2.1 of the Implementation 

Plan for Subpart A (DOE/WIPP 

00-3121:COB-A2006-A) explains 

DOE’s plan to fulfill this 

requirement. Annual Site 

Environmental Report (DOE/WIPP 

06-2225:COB-A2007-A) page ii 

demonstrates that DOE implements 

groundwater surveillance, biota 

sampling and off-site air 

monitoring programs. 

Sat. 

Boundary of compliance

6 Does DOE demonstrate compliance at the 

“exclusive use area” boundary? 

If not, does DOE justify changing this 

boundary? 

EPA 402-R-97-001 

Section 2.5, Page 6. 

EPA 402-R-97-001 

Section 2.5, Page 7 

Section 3.1 of DOE/WIPP 00-3121 

states that the “Exclusive Use 

Area” will be used as the boundary 

for 40 CFR 191 Subpart A 

compliance. 

Sat. 

Location of maximally exposed individual

7 Does DOE examine radiation doses to 

individuals at any offsite point where there 

is a residence, school, business, or office? 

(Such as grazing, mining, or oil drilling in 

the vicinity.) 

EPA 402-R-97-001 

Section 2.6.1, Page 

8 

DOE/WIPP 06-2225 Section 1.3.2 

and the Annual NESHAP report 

(COB-A2007-AC) demonstrate 

that DOE considers doses at 

appropriate offsite points, such as 

Smith Ranch located 7.5 km away 

in the WNW sector. 

Sat. 

8 Does DOE analyze potential exposure 

pathways and examine demographic 

information and conduct field 

investigations to identify the location of 

actual individual who could be exposed via 

those pathways? 

EPA 402-R-97-001 

Section 2.6.1, Page 

8 

DOE/WIPP 06-2225 Section 1.3.2 

and the Annual NESHAP report 

(COB-A2007-AC) page 7 

demonstrate that DOE considers 

doses at appropriate offsite points, 

such as Smith Ranch located 7.5 

km away in the WNW sector of 

WIPP. 

Sat. 

9 Does DOE conduct separate analyses of 

potential dose received from each exposure 

pathway? 

Then does DOE assume that a member of 

the public resides at the single geographic 

point on the surface where the maximum 

dose would be received? 

EPA 402-R-97-001 

Section 2.6.1, Page 

8 

DOE/WIPP 06-2225:COB-A2007-

A Section 1.3.2 and the Annual 

NESHAP report (COB-A2007-AC) 

page 7 demonstrate that DOE 

considers doses at appropriate 

offsite points, such as Smith Ranch 

located 7.5 km away in the WNW 

sector of WIPP. 

Sat. 
10

# CHECKLIST QUESTION June 2007 40 CFR 191.03 Subpart A

Personal parameters EPA Citation Comments (Objective Evidence) Result

10 Does DOE assume that the individual 

exhibits personal characteristics of the 

“reference man” when evaluating 

radiation dose to the maximally exposed 

individual? 

EPA 402-R-97-001 

Section 2.6.2, Page 

8 

Section 3.2 of the Implementation 

Plan for Subpart A (DOE/WIPP 00-

3121:COB-A2006-A) describes the 

“reference man” parameters as 

described in the CAP88-PC computer 

code. Annual NESHAP report 

(COB-A2007-AC) Enclosure 2 

demonstrates that “reference man” is 

used to evaluate radiation dose. 

Sat. 

Calculation of dose - Modeling –

Parameters

11 Does DOE provide both whole body 

radiation dose and critical organ radiation 

dose for the maximally exposed individual 

(or a hypothetical individual conservatively 

located at a point of higher exposure)? 

EPA 402-R-97-001 

Section 2.7.1, Page 

8 

Annual NESHAP report (COBA2007-AC) Enclosure 2 

demonstrates that DOE appropriately 

fulfills this requirement. 

Sat. 

12 Does DOE calculate radiation doses 

including all release points and reflecting 

evaluation of all exposure pathways? 

EPA 402-R-97-001 

Section 2.7.1, Page 

8 

Section 2.1 of DOE/WIPP 00-3121 states 

that the air pathway is the most credible 

but other exposure pathways are 

monitored. Annual NESHAP report 

(COB-A2007-AC) page 5 demonstrates 

that all release points are evaluated. 

Sat. 

13 Does DOE use computer modeling to 

calculate radiation doses for compliance 

with the Subpart A standard? 

EPA 402-R-97-001 

Section 2.7.2, Page 

9 

Section 3.2 of DOE/WIPP 00-3121 states 

that a computer model will be used to 

calculate radiation doses. Annual 

NESHAP report (COB-A2007-AC) 

Enclosure 2 demonstrates that DOE is 

using computer modeling. 

Sat 

14 Does DOE use CAP88-PC to perform 

dose calculations? 

EPA 402-R-97-001 

Section 2.7.2, Page 

9 

Section 3.2 of DOE/WIPP 00-3121 states 

that CAP88-PC is used for dose 

calculations. Annual NESHAP report 

(COB-A2007-AC) demonstrates that 

DOE is using CAP88-PC. 

Sat. 

15 Does DOE use an alternate model for 

calculating radiation doses? If so, does 

DOE justify such usage? 

EPA 402-R-97-001 

Section 2.7.2, Page 

10 

Section 3.2 of DOE/WIPP 00-3121 states 

that DOE uses the atmospheric dispersion 

code (GXQ) to determine concentrations 

for accidental releases. GXQ is a 

reasonable choice for these calculations. 

Sat. 

16 Does DOE adequately supported 

exposure parameters used in dose 

calculations? 

EPA 402-R-97-001 

Section 2.7.3, Page 

10 

Annual NESHAP report (COB-A2007-

AC) demonstrates that DOE is using 

appropriate parameters in dose 

calculations. 

Sat. 
11

# CHECKLIST QUESTION June 2007 40 CFR 191.03 Subpart A

Calculation of dose - Modeling - Parameters EPA Citation Comments (Objective Evidence) Result

17 Does DOE document that “conservative 

simplifying assumptions” are used in the 

radiation dose calculations? 

EPA 402-R-97-001 

Section 2.7.3, Page 

10 

Annual NESHAP report (COBA2007-AC) demonstrates that 

DOE is using conservative 

simplifying assumptions in dose 

calculations. 

Sat. 

18 Are DOE’s exposure parameters as 

conservative as the following? 

For a maximally exposed individual 

located at a residence, assumed continuous 

exposure (24 hours per day). 

For a maximally exposed individual 

located at a business, office, or school, 

assume exposure of 8 hours per day. 

Assume individuals consume 2 liters per 

day of drinking water from an underground 

source of drinking water. 

Assume inhalation rate for air to be 9x105

cm3/hr. 

Assume ingestion rate of meat to be 85 

kg/yr. 

Assume ingestion rate of leafy vegetables 

to be 18 kg/yr. 

Assume ingestion of milk to be 112 

liter/yr. 

Assume ingestion rate of produce to be 176 

kg/yr 

EPA 402-R-97-001 

Section 2.7.3, Page 

10 

Section 3.2 of the Implementation 

Plan for Subpart A (DOE/WIPP 

00-3121:COB-A2006-A) states 

that DOE is using these values as 

exposure parameters. The Annual 

NESHAP report (COB-A2007-AC) 

demonstrates that DOE is using 

these parameters in dose 

calculations. 

Sat. 
12

# CHECKLIST QUESTION June 2007 40 CFR 191.03 Subpart A

Emissions and Environmental Monitoring - Air EPA Citation Comments (Objective Evidence) Result

19 Does DOE demonstrate that effluent flow 

rate measurements are made using 

Reference Method 2 of Appendix A to 40 

CFR Part 60 to determine velocity and 

volumetric flow rate for stacks and large 

vents? 

EPA 402-R-97-001 

Section 3.1, Page 

11, (1(i)) 

QAPP For Sampling Emissions 

(WP 12-RC.01:COB-A2006-F) 

Section 4.1 documents that this 

requirement is appropriately 

implemented at WIPP. 

Sat. 

20 Does DOE demonstrate that effluent flow 

rate measurements are made using 

Reference Method 2a of Appendix A to 40 

CFR 60 to measure flow rates through 

pipes and small vents? 

EPA 402-R-97-001 

Section 3.1, Page 

11, (1(ii)) 

Not applicable at WIPP. Duct 

diameter associated with WIPP 

exhaust point exceeds the 40 CFR 

60 requirements. 

NA 

21 Does DOE demonstrate that the frequency 

of flow rate measurements depend on the 

variability of the effluent flow rate? 

Note: For variable flow rates, continuous 

or frequent flow rate measurements are 

expected to be made. For relatively 

constant flow rates, only periodic 

measurements are expected. 

EPA 402-R-97-001 

Section 3.1, Page 

11, (1(iii)) 

Implementation Plan for Subpart A 

(DOE/WIPP 00-3121:COBA2006-A) Section 3.3.1 states that 

DOE uses continuous air 

monitoring at WIPP and does not 

need to consider this requirement. 

NA 

22 Does DOE demonstrate that radionuclides 

to be directly monitored or extracted, 

collected and measured using Reference 

Method 1 of Appendix A to 40 CFR Part 

60 for selected monitoring or sampling 

sites? 

EPA 402-R-97-001 

Section 3.1, Page 

11, (2(i)) 

DOE uses 40 CFR 61 Appendix B 

Method 114. WP 12-RC.01 

documents in Section 4.1 the 

location of sampling sites. 

Sat. 
13

# CHECKLIST QUESTION June 2007 40 CFR 191.03 Subpart A

Emissions and Environmental Monitoring - Air EPA Citation Comments (Objective Evidence) Result

23

a 

Does DOE demonstrate that radionuclides to be 

directly monitored or extracted, collected and 

measured continuously with an in-line detector 

capable of distinguish relevant radionuclides? 

As an acceptable alternative to direct radiation 

monitoring, the effluent air stream may be 

continuously sampled such that analysis of 

filters or other collectors will provide an 

accurate estimate of emissions from a known 

flow rate during a fixed sampling time. 

EPA 402-R97-001 

Section 3.1, 

Page 11, (2(ii)) 

DOE uses periodic monitoring at WIPP to 

show compliance with 40 CFR 191 Subpart 

A. However, Implementation Plan for 

Subpart A (DOE/WIPP 00-3121:COBA2006-A) Section 3.3.1 states that DOE 

uses continuous monitoring. DOE/WIPP 

00-3121 Sections 3.5 and 3.3.5 document 

relevant radionuclides at WIPP. Annual 

NESHAP report (COB-A2007-AC) 

demonstrates that these radionuclides are 

sampled and tested. 

NA 

23

b 

Does DOE demonstrate that representative 

samples of the effluent stream are 

withdrawn from the sampling site? “...The 

need for continuous sampling is applicable 

to batch processes when the unit is in 

operation....” The WIPP is a batch 

(continuous) process disposing of 

radioactive waste therefore continuous 

sample is appropriate. 

EPA 402-R97-001 Section 

3.1, Page 11, 

(2(ii)) 

Environmental Monitoring Plan 

(DOE/WIPP 99-2194:COB-A2007-1 and 

COB-A2007-1) Section 5.2.4 and 

DOE/WIPP 00-3121:COB-A2006-A 

Section 3.3.2 states that sample sites will 

acquire representative samples. Recent 

probe pull photographs at Station A (COBA2007-S18 and –S18a for example) appear 

to show that the probe has salt loading and 

that the probe, in some cases, may not to 

pass minimum acceptance criteria (COBA2007-S18a). Even though salt loading 

continues to be a problem at Station A DOE 

continues to aggressively increase the probe 

cleaning schedule whenever salt loading 

increases. DOE is working on techniques to 

improve prediction of salt loading and 

changing probes accordingly. 

Sat. 

24 Does DOE demonstrate that radionuclides 

are collected and measured using 

procedures based on the principles of 

measurement described in Appendix B, 

Method 114 of 40 CFR 61? If not, does 

DOE demonstrate that the Administrator 

has approve the method used? 

EPA 402-R97-001 

Section 3.1, 

Page 12, 

(2(iii)) 

The QAPP for Sampling Emissions 

(WP 12-RC.01:COB-A2006-F) Section 

1.0 documents that DOE used these 

principles. 

Sat 

25 If DOE is using the “Shrouded Probe”, 

does DOE demonstrate that this alternative 

method is being used according to the 

guidance provide in “An Explanation of 

Particle Sampling in a Moving Gas Stream 

Within a Duct Using an Unshrouded and 

Shrouded Probe”? 

EPA 402-R97-001 

Section 3.1, 

Page 12, 

(2(iii)(a)) 

An Assessment of the WIPP Shrouded 

Probe Against EPA Approval Criteria for 

Use of Single Point Sampling with the 

Shrouded Probe HA:98:0100 (Included in 

August 2000 Inspection Report, A-98-49, 

II-B3-12, EPA Approval letter (COB 191AAO-2000: COB-A2006-3) documents 

DOE’s evaluation of the Shrouded Probe 

and its compliance with the EPA criteria. 

Single Point Representative Sampling with 

Shrouded Probes (LA-12612-MS:COBA2006-4) documents how the shrouded 

probe was qualified for use at WIPP. 

Sat. 
14

# CHECKLIST QUESTION June 2007 40 CFR 191.03 Subpart A

Emissions and Environmental Monitoring - Air EPA Citation Comments (Objective Evidence) Result

26 Does DOE’s quality assurance program 

meet the performance requirements 

described in Appendix, Method 114 of 40 

CFR Part 61? 

EPA 402-R-97-001 

Section 3.1, Page 

12, (2(iv)) 

QAPP for Sampling Emissions (WP 

12-RC.01:COB-A2006-F) Section 1.0 

documents DOE quality assurance 

requirements. These meet the 

requirements of 40 CFR 61. 

Implementation Plan for Subpart A 

(DOE/WIPP 00-3121:COB-A2006-A) 

Section 4.0 states that DOE 

implements NQA requirements which 

are equivalent to Method 114. 

Sat. 

27 If it is impractical to measure the effluent flow 

rate in accordance with the method(s) in Section 

3.1(1) or to monitor or sample extraction 

according to methods in Section 3.1(2) has 

DOE demonstrated that the use of alternative 

effluent flow rate measurement or site selection 

and sample extraction are appropriate and that 

the alternate method are used provided the 

following: 

(i) DOE shows that methods in Section 3.1(1) 

or (2) are impractical; 

(ii) DOE shows the alternative procedure will 

not significantly underestimate the emissions; 

(iii) DOE shows the alternative procedure is 

fully documented; and 

(iv) DOE has received prior approval from 

EPA. 

EPA 402-R-97-001 

Section 3.1, Page 

12, (3(i) to 3(iv)) 

See question #19, DOE uses 

Section 3.1 (1)(i) of EPA 402-R97-001 page 11. 

NA. 

28 Does DOE demonstrate that radionuclide 

emission measurements are in 

conformance with the methods in Section 

3.1(1) and (2) to be made at all release 

points which have a potential to discharge 

radionuclides into the air in quantities 

which could cause a combined annual dose 

equivalent in excess of 1% of the dose 

limit in Subpart A? 

EPA 402-R-97-001 

Section 3.1, Page 

12 and page 13, 

(4(i)) 

Section 3.3.3 of DOE/WIPP 00-

3121 documents DOE’s 

compliance with this requirement. 

Sat. 

29 Does DOE demonstrate that all 

radionuclides which could contribute 

greater than 10% of the combined annual 

dose equivalent for a release point are 

being measured? 

EPA 402-R-97-001 

Section 3.1, Page 

13, (4(i)) 

Section 3.3 of DOE/WIPP 00-3121 

documents DOE’s compliance with 

this requirement. Section 2.0 of 

the Periodic Confirmatory 

Measurement Protocol 

(DOE/WIPP 97-2238:COBA2006-B) discusses release points 

measured confirm compliance with 

this requirement. 

Sat. 
15

# CHECKLIST QUESTION June 2007 40 CFR 191.03 Subpart A

Emissions and Environmental Monitoring - Air EPA Citation Comments (Objective Evidence) Result

30 If DOE uses alternative procedures to 

determine emissions, does DOE 

demonstrate that they have prior EPA 

approval? 

EPA 402-R-97-001 

Section 3.1, Page 

13, (4(i)) 

DOE uses the shrouded sampling 

probe as an alternative method. 

EPA has approved this alternative 

method (COB-M2006-3) 

NA 

31 Does DOE demonstrate that for other 

release points which have a potential to 

release radionuclides into the air it has 

performed periodic confirmatory 

measurements to verify the low emissions? 

EPA 402-R-97-001 

Section 3.1, Page 

13, (4(i)) 

DOE does not have other release 

points which have a potential to 

release radionuclides. CH 

(DOE/WIPP-95-2065:COBA2007-C1) and RH (DOE/WIPP06-3174:COB-A2007-C2) Waste 

Documented Safety Analysis 

documents these conclusions. 

NA 

32 Does DOE demonstrate that an evaluation 

has been done to evaluate the potential for 

radionuclide emissions for a release point? 

EPA 402-R-97-001 

Section 3.1, Page 

13, (4(ii)) 

Section 2.0 of the Periodic 

Confirmatory Measurement 

Protocol (DOE/WIPP-97-

2238:COB-A2006-B) documents 

this evaluation and that WIPP has 

three release points. 

NA 

33 Does DOE demonstrate that estimated 

radionuclide release rates are based on 

discharge of effluent stream that would 

result if all pollution control equipment did 

not exist, but the facilities operations were 

otherwise normal? 

EPA 402-R-97-001 

Section 3.1, Page 

13, (4(ii)) 

Section 5.2.4 of the WIPP 

Environmental Monitoring Plan 

(DOE/WPP 99-2194:COB-A2006-

1 and COB-A2007-1) states: 

“Station A exhausts unfiltered air 

from the underground repository to 

the atmosphere. Station B exhausts 

HEPA filtered air from the 

underground repository to the 

atmosphere when in Filtration 

Mode of operation. Station C 

exhausts HEPA filtered air from 

the Waste Handling Building to the 

atmosphere.” Stations B and C 

uses pollution control equipment, 

therefore item 33 is not fulfilled. 

However, because of the nature of 

these sample locations and that 

they are filtered continuously this 

approach is appropriate; therefore 

the Agency agrees that DOE’s 

sample methods are adequate. 

Sat. 
16

# CHECKLIST QUESTION June 2007 40 CFR 191.03 Subpart A

Environmental Measurements (Page 1) EPA Citation Comments (Objective Evidence) Result

34 Does DOE demonstrate that environmental 

measurements of concentrations of 

radionuclides in air at the critical receptor 

locations are used as an alternative to air 

dispersion calculations in demonstrating 

compliance with the standard? 

EPA 402-R-97-001 

Section 3.1, Page 

13, (5) 

DOE does not use environmental 

monitoring as an alternative to 

comply with 40 CFR 191.03 

Subpart A. DOE samples at 

release points. 

NA 

35 Does DOE demonstrate that air at the point 

of measurement is continuously sampled 

for collection of radionuclides if 

environmental measurements are used? 

EPA 402-R-97-001 

Section 3.1, Page 

13, (5(i)) 

NA 

36 Does DOE demonstrate that the 

environmental measurement program is 

appropriately designed to collect and 

measure specifically those radionuclides 

which are major contributors to the annual 

radiation dose from the facility? 

EPA 402-R-97-001 

Section 3.1, Page 

13, (5(ii)) 

NA 

37 Does DOE demonstrate that radionuclide 

concentrations which would cause an 

annual dose equivalent of 10% of the 

standard are readily detectable and 

distinguishable from background? 

EPA 402-R-97-001 

Section 3.1, Page 

13, (5(iii)) 

NA 

38 Does DOE demonstrate that a quality 

assurance program that meets the 

performance requirements described in 40 

CFR Part 61, Appendix B, Method 114 is 

conducted for environmental 

measurements? 

EPA 402-R-97-001 

Section 3.1, Page 

13, (5(iv)) 

 NA 
17

# CHECKLIST QUESTION June 2007 40 CFR 191.03 Subpart A

Environmental Measurements (Page 2) EPA Citation Comments (Objective Evidence) Result

39 Does DOE demonstrate that EPA has 

granted prior approval for the use of 

environmental measurements to 

demonstrate compliance with the standard? 

EPA 402-R-97-001 

Section 3.1, Page 

13, (5(v)) 

DOE has not requested approval to 

use environmental measurements. 

NA 

Emissions and Environmental 

Monitoring - Other Media

40 Does DOE demonstrate that environmental 

monitoring of other release points or 

critical receptor locations to confirm air 

exhaust as the only release pathway? 

EPA 402-R-97-001 

Section 3.2, Page 

14. 

Implementation Plan for Subpart A 

(DOE/WIPP 00-3121:COBA2006-A) Section 2.1 states; 

“However, to confirm that the air 

pathway is the only credible 

pathway for radiological releases, 

WIPP implements a radiological 

ground water surveillance program, 

biota sampling program and offsite radiological air monitoring 

program.” Annual Site 

Environmental Report (DOE-WIPP 

06-2225:COB-A2007-A) Chapter 4 

demonstrates that DOE’s 

environmental program monitors 

other release points and critical 

receptor locations. 

Sat. 
18

# CHECKLIST QUESTION June 2007 40 CFR 191.03 Subpart A

Compliance Reporting EPA Citation Comments (Objective Evidence) Result

41 Does DOE demonstrate compliance with 

the Subpart A standard by showing that 

the annual radiation dose to any member 

of the public in the general environment 

falls below the regulatory limits? 

EPA 402-R-97-001 

Section 4.2, Page 

15. 

Section 5.0 of the Implementation 

Plan for Subpart A (DOE/WIPP 00-

3121:COB-A2006-A) documents that 

DOE’s plans to report results yearly. 

The Annual NESHAP (COB-A2007-

AC) report demonstrates that DOE 

reports results yearly. 

Sat. 

42 Does DOE report results of monitoring 

and the dose calculations for each 

reporting period? 

EPA 402-R-97-001 

Section 4.2, Page 

15 

Section 5.0 of DOE/WIPP 00-3121 

documents that DOE’s plans to report 

results. The Annual NESHAP Report 

demonstrates that DOE reports results 

of monitoring and dose results yearly. 

Sat. 

43 Does DOE demonstrate that monitoring is 

performed each calendar year of facility 

operation, and that radiation doses are 

calculated after the end of each year? 

EPA 402-R-97-001 

Section 4.2, Page 

15 

Section 5.0 of DOE/WIPP 00-3121 

documents that DOE’s plans to report 

results yearly. The Annual NESHAP 

Report demonstrates that DOE reports 

results of monitoring activities and 

dose is calculated yearly. 

Sat. 

Notification of construction or modification.

44 Does DOE demonstrate that they have 

provided the EPA written notification of 

any planned construction or modification 

to the WIPP facility, prior to commencing 

any such activity, if it results in an 

increase in the rate of emissions of 

radionuclides during operation? 

EPA 402-R-97-001 

Section 4.3, Page 

16. 

Section 5.0 of DOE/WIPP 00-

3121 documents that DOE’s plans 

to report results yearly. The 

Annual NESHAP Report 

demonstrates that DOE reports 

planned construction and 

modification during the year. 

Sat. 

45 Does DOE demonstrate that advanced 

notification was not needed for construction 

and modification if the radiation dose caused 

by all the emissions from the new construction 

or modification is less than 1% of the Subpart 

A dose limits? 

EPA 402-R-97-001 

Section 4.3, Page 

16 and page 17. 

Section 5.0 of DOE/WIPP 00-

3121:COB-A2006-A documents 

that DOE’s plans to report results 

yearly. 

Sat. 

Record Keeping

46 Does DOE demonstrate documentation is 

sufficient to allow the Agency to verify 

the correctness of the determination made 

concerning the WIPP’s compliance with 

Subpart A? 

EPA 402-R-97-001 

Section 4.4, Page 

17. 

Through its various documents, 

Subpart A implementation plan, its 

Annual NESHAP Report, and many 

procedures that support Subpart A 

activities, DOE demonstrate that 

documentation is sufficient to allow 

EPA to verify compliance with 

Subpart A. 

Sat. 
19

Attachment B 

Table of Documents Reviewed