### 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) con ducted an annual inspection of the**  **Department of Energy (DOE) Waste Isolation Pilot Pl ant (WIPP) July 10 to July 12, 2007 as part**  **of our continued oversight program. This inspectio n 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 re leases to the public due to normal**  **waste disposal operations and any unplanned or acci dental releases that might occur during**  **disposal operations. EPA reviewed DOE’s activities related to underground continuous air**  **monitors (CAM) false alarms examined during the las t 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 em ission control devices and methods used**  **to estimate radiation doses to the public. In addi tion, 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 mo nitoring program during the past**  **year, and responded aggressively and appropriately to Station A issues. Moisture and salt**  **loading continues to challenge the Station A sampli ng location. EPA verified that DOE**  **increased probe cleaning frequency as needed and co ntinued to work toward a solution to this**  **persistent problem. DOE continues to have an effec tive 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 inspect ion.** 

2.0 Inspection Scope

**The scope of this inspection was to verify that WI PP continues to effectively capture,**  **measure, and calculate radiation doses to members o f the public during waste disposal**  **operations. Inspection activities included an exam ination 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 sp ecific review the impact of moisture**  **and salt loading on the sampling location at Statio n 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, T homas 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 pr ogram at WIPP during the past year:** 

**- Upgraded Station A flow control and differential pressure equipment,** 

**- First receipt of RH waste, January 28, 2007; adde d RH waste isotopics to sampling program,** 

**- Procedures for both effluent monitoring and labor atory analysis have had minor changes,** 

**- Changes related to the underground CAMs, and**

**- Developing processes to analyses Station A shroud ed 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 v erify effective implementation of**  **DOE/WTS procedures. EPA reviewed procedures and im plementation 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; o bserved 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 ai r**  **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 fa ce.**  **This caused electronic noise resulting in the High- High alarms (COB-A2007-S7).” In response**  **to these problems DOE initiated the following chang es: 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 t he 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 Shroude d Probes (Figure 2) in the air**  **exhaust of Panel 4 and will be using these in futur e panels. One main advantage of these CAMs**  **is that they sense pressure changes across the samp le 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 R ADOS 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 n ew 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, Aut o-Filter Changer, RADOS Spectra Display



### EPA believes that the underground samplers at Stati **on 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 undergrou**  **nd 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 wit h 40 CFR 191, Subpart A – Station A. This**  **problem may negatively impact DOE’s ability to acqu ire 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 sam pling methods, some studies have shown that**  **performance efficiency can be impaired by excessive salt loading (COB-A2006-ZE, COB**  **A2006-ZB, and COB-A2006-ZA).**

**As noted in 2006 in EPA’s inspection report the do cument,**  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 fo**  **r the shrouded probe is the inlet effective diameter. Decreasing the inlet diameter by salt lo**  **ading 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 determini**  **ng the shrouded probe performance. DOE has been using the criteria of one-third occlusion of t**  **he waistline space and two-thirds occlusion of the probe inlet to determine if a probe is operatin**  **g effectively (COB-A2006-V, Section 8.3).**

**In 2006 DOE/WTS and EPA had extensive discussions d uring inspection interviews to**  **attempt to determine the overall effectiveness of e ffluent sampling at Station A. Ultimately,**  **EPA determined that it was not totally clear that S tation 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 represe ntative of the air flow from the underground**  **by increasing the frequency of preventive maintena nce.** 

### 5

**- re-evaluation of the shrouded probe acceptance cr iteria.** 

**- development of a probe inlet measurement techniqu e to be used for acceptance determinations.** 

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

**consideration of alternatives to Station A.**

**During our 2007 inspection EPA reviewed DOE’s prog ress 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 predic t when a probe may be loaded with salt and**  **needs to be changed based on meteorological data an d attempted to develop a more precise**  **method to measure the occlusion of the shrouded pro be 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 sal t**  **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 s**  **ee 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 p ixels recorded on a photograph in a selected**  **area; therefore by using this method DOE may be abl e 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 act ivities 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 attem pting 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 r**  **eporting 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 l**  **imits expressed in Section 191.03. This inspection is conducted under the authority of 40 C**  **FR 191, Subpart A.**

Scope **: Inspection activities will include an examination o**  **f the description of monitoring and sampling equipment both on and off site, and in the undergro**  **und.**

**A particular focus of this inspection will be the c ontinued challenges of moisture and salt built**  **up on the shrouded probes at Station A and its pote ntial impact on the quality and adequacy of**  **samples collected at Station A.**

**EPA inspectors also wish to begin an in-depth evalu ation of the Subpart A sampling**  **requirements for the handling and disposal of RH wa ste at the WIPP site** 

Location **: This inspection will be held at the WIPP facility l**  **ocated twenty-six miles south east of Carlsbad, New Mexico and the surrounding vicinity as needed.** 

Duration **: EPA expects to complete its inspection in three day**  **s. Each day will begin with an opening meeting at 8:00 a.m. and end at 5:00 p.m. with a cl**  **oseout session.**

Expected Dates **: Week of July 9, 2007.**

Documents Required for Review: **DOE must provide the most recent annual Safety Anal ysis Report, information that describes**  **how measurements are taken, and complete documentat ion that shows how compliance**  **calculations are performed with an explanation of a ll input parameters and their derivation and**  **all related to Subpart A requirements (such as curr ent 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 require d, 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-R**

**97-001 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-R** 

**97-001 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 (COB**  **A2007-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:COB**  **A2007-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-R** 

**97-001 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 o n**  **which contaminated particles have been deposited, swimming in ponds in which radionuclides have**  **been deposited are considered? EPA 402-R** 

**97-001 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 (COB** 

**A2007-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 (COB** 

**A2007-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 9x10 5** 

**cm 3**  **/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:COB A2006-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-R**

**97-001 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:COB A2006-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-R**

**97-001 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 (COB**  **A2007-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 (COB**  **A2007-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-R**

**97-001 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-R** 

**97-001 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 191A**  **AO-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:COB**  **A2006-4) 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-R 97-001 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:COB**  **A2006-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:COB** **A2007-C1) and RH (DOE/WIPP 06-3174: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:COB A2006-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 off**  **site 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