DOCKET NO: A-98-49 

Item: II-B3-97

Monitoring Inspection Report

INSPECTION No. EPA-WIPP-6.06-20b 

OF THE 

WASTE ISOLATION PILOT PLANT 

June 20 to June 22, 2006 

U. S. ENVIRONMENTAL PROTECTION AGENCY 

Office of Radiation and Indoor Air 

Center for Federal Regulation 

1200 Pennsylvania Avenue, NW

Washington, DC 20460 

September 2006
 Table of Contents 

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

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

3.0 Inspection Team, Observers, and Participants...........................................................................2 

4.0 Performance of the Inspection ...................................................................................................3 

 4.1 Monitoring of Geomechanical Parameters .............................................................................3 

 4.2 Monitoring of Hydrological Parameters .................................................................................4 

 4.3 Monitoring of Waste Activity Parameters ..............................................................................4 

 4.4 Monitoring of Drilling Related Parameters ............................................................................4 

 4.5 Monitoring of Subsidence Parameters ....................................................................................5 

5.0 Summary of Findings.................................................................................................................5 

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 inspection of the 

Department of Energy’s (DOE) Waste Isolation Pilot Plant (WIPP) from June 20 to June 22, 

2006, as part of our continuing WIPP oversight program. The purpose of this inspection was to 

verify that DOE continues to adequately monitoring the ten parameters listed in the Compliance 

Certification Application (CCA), Volume 1, Section 7.0, in particular Table 7-7 (See Table 1, 

COB-M2006-1). Attachment A contains the checklist and the inspection plan used by the EPA 

inspector, and Attachment B lists documents reviewed by the EPA inspector. 

 The inspection examined the implementation of monitoring for geomechanical, 

hydrological, waste activity, drilling related, and subsidence parameters. The EPA inspector 

toured locations where measurements are taken, reviewed parameter databases, and reviewed 

documents and procedures directing these monitoring activities. 

 The inspector found that DOE, through its contractor Washington TRU Solutions (WTS), 

effectively implemented the monitoring programs at WIPP for all areas. EPA did not have any 

findings or concerns. The inspector also confirmed that the results of DOE monitoring programs 

are reported annually. 

2.0 Scope

 The WIPP Compliance Criteria (40 CFR Part 194.42(a)) require DOE to “conduct an 

analysis of the effects of disposal system parameters on the containment of waste in the disposal 

system.” The results of these analyses were included in the 1996 Compliance Certification 

Application (CCA), confirmed in the 2004 Compliance Recertification Application (CRA), and 

were used to develop pre-closure and post-closure monitoring requirements. 

 Volume 1, Section 7.0, of the CCA documented DOE’s analysis of monitoring 

parameters. Table 7-7 of the CCA lists the ten parameters that DOE determined may affect the 

disposal system. These parameters are grouped into major categories and listed in Table 1. 

Table 1 - Monitored Parameters

Geomechanical Parameters- Waste Activity Parameter- 

 -Creep closure, -Waste Activity 

 -Extent of deformation, 

 -Initiation of brittle deformation, and Subsidence Parameter- 

 -Displacement of deformation features. -Subsidence measurements 

Hydrological Parameters- Drilling Related Parameters- 

 -Culebra groundwater composition and -Drilling rate and 

 -Change in Culebra groundwater flow -The probability of encountering a 

 direction. Castile brine reservoir. 
2 

 EPA accepted these ten monitoring parameters in the 1998 Certification Decision and 

confirmed them in the 2006 Recertification Decision. This inspection was performed under 

authority of 40 CFR 194.21, which authorizes EPA to verify the continued effectiveness of the 

parameter monitoring program at WIPP. Inspection activities included an examination of 

monitoring and sampling equipment both on and off site, and in the underground. EPA also 

reviewed numerous sampling procedures and measurement techniques and verified 

implementation of an effective quality assurance program, see the extensive document list in 

Attachment B. 

3.0 Inspection Team, Observers, and Participants

 The inspection consisted of four EPA staff. Four members of the New Mexico oversite 

group also observed the inspection, Tom Kline, Robert Blohm, John Hascherts, and Dean Foster. 

Inspection Team Member Position Affiliation

Chuck Byrum Inspection Leader EPA 

Barnes Johnson Observer EPA 

Nick Stone Observer EPA 

Tom Peake Observer EPA 

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

DOE/Contractor Participates

Linda Frank-Supka Ed Flynn 

Joel Siegel Don Harward 

Sam Dominguez Randy Elmore 

John VandeKraats Art Chavez 

Steve Casey Mansour Akbarzadeh 

Dave Kump Larry Madl 

Daryl Mercer Dave Hughes 

4.0 Performance of the Inspection 

The inspection began on Tuesday, June 20, 2006, with an opening meeting where 

changes in the parameter monitor programs since the previous inspection were discussed by site 

staff. The underground, where geomechanical convergence measurements are taken, was also 
3 

inspected. On June 21, 2006 the inspection continued with interviews and demonstrations of 

various aspects of each parameter monitoring area. On June 22, 2006 the EPA inspector 

examined the database(s) used to store Delaware Basin parameters and the WIPPP Waste 

Information System (WWIS) waste computer database system. The inspection closeout meeting 

was held on June 22, 2006. 

 The EPA inspector reviewed three fundamental areas to verify continued implementation 

of the DOE parameter monitoring program during the pre-closure phase: 1) written plans and 

procedures, 2) quality assurance procedures and records, and 3) results of the monitoring 

program in the form of raw data, intermediate reports, and final annual reports, if appropriate. 

The inspection checklist in Attachment A provides details of these inspection activities. 

The EPA inspector reviewed various activities to verify effective procedure 

implementation. The inspector observed a demonstration of the WWIS and reviewed the 

Delaware Basin Drilling Surveillance Program, Groundwater Monitoring Program, and the 

Geomechanical Monitoring Program. 

4.1 Monitoring of Geomechanical Parameters

 DOE committed to measure four geomechanical 

parameters in the CCA: creep closure, extent of deformation, 

initiation of brittle deformation, and displacement of 

deformation features. WIPP has four programs that supply 

information for these four parameters: the geomechanical 

monitoring program, the geosciences program, the ground 

control program, and the rock mechanics program. These 

programs are documented in the WIPP Geotechnical 

Engineering Program Plan, WP 07-01 (COB-M2006-D). The 

results of the geotechnical program are reported in the 

Geotechnical Analysis Report for July 2004 - June 2005, 

DOE/WIPP-0-3177, Volumes 1 and 2 (COB-M2006-A and -

A2). 

 The EPA inspector toured and reviewed underground 

instrumentation in Panels 3 and 4, the computer database, and 

field data sheets used to record raw measurement data. EPA 

also examined output convergence, roof-to-floor 

measurements, check prints to verify implement of the 

measurement plan (COB-M2006-S10, -S11, -S12, and -S13). 

While underground the inspector observed the acquisition of 

convergence using the new digital Geokon extensometer 

(Figure 1) and load cell measurements. 

 

Figure 1 Convergence Measurement
4 

4.2 Monitoring of Hydrological Parameters

 DOE committed to measure two hydrological parameters in the CCA: Culebra 

groundwater composition and changes in the Culebra groundwater flow direction. Related 

parameters are measured and documented in the WIPP environmental monitoring program. 

These programs are documented in the WIPP Groundwater Monitoring Program Plan, WP 02-1 

(COB-M2006-C). Results of this program are documented in the Waste Isolation Pilot Plant 

2004 Site Environmental Report, DOE/WIPP 05-2225 (COB-M2006-O). This document 

describes the groundwater monitoring program and reports results for the previous year. 

 

 During the 2006 inspection the EPA inspector requested information about changes in the 

program since last year. Joel Siegel noted that three new Culebra wells were drilled and 13 wells 

plugged (COB-M2006-S2). The current well monitor network consist of 41 Culebra, 11 

Magenta, 4 dual Culebra/Magenta completions, 1 Dewey Lake, 2 Bell Canyon, and 16 shallow 

Santa Rosa/Dewey Lake wells. 

4.3 Monitoring of Waste Activity Parameters

 DOE committed to monitor the activity of waste emplaced in the CCA. This parameter is 

part of the extensive database collected for each container shipped to WIPP and is stored in the 

WIPP Waste Information System (WWIS). The WWIS is a software system that screens waste 

container data and provides reports on the Transuranic (TRU) waste sent to WIPP. The 

requirements for the WWIS are discussed in the WIPP Waste Information Program and System 

Data Management Plan, WP 08-NT.01 (COB-M2006-G). 

 WWIS staff demonstrated that the WWIS can receive data and that the WWIS can 

generate needed reports. CBFO has committed to annual waste activity reports. The inspector 

obtained copies of the Nuclide Report (COB-M2006-S21). 

4.4 Monitoring of Drilling Related Parameters

 DOE committed to measure two drilling related parameters in the CCA: the drilling rate 

and the probability of encountering a Castile brine reservoir. These parameters are measured as 

part of the Delaware Basin Drilling Surveillance Plan, WP 02-PC.02 (COB-M2006-F). This 

surveillance program measures and records many parameters related to drilling activities around 

the WIPP site. The results of the surveillance program are documented annually in the Delaware 

Basin Annual Report, DOE/WIPP 99-2308 (COB-M2006-N). 

 Inspectors reviewed the drilling surveillance database, examined drilling rate changes, 

and permitted and active injection wells while interviewing Dave Hughes. Inspectors received 

oil well scout tickets and maps of recent activity near WIPP (COB-M2006-S16, -S17, -S18, -S19 

and –S20). 
5 

4.5 Monitoring of Subsidence Parameters

 DOE committed to measure subsidence at the WIPP site. This parameter is documented 

as part of the WIPP Underground and Surface Surveying Program, WP 09-ES.01 (COB-M2006-

B). DOE performs subsidence surveys at the site annually during pre-closure operations. The 

results of this program are reported annually in the WIPP Subsidence Monument Leveling 

Survey – 2005, DOE/WIPP 06-2293 (COB-M2006-E). 

 Ben Zimmerly showed the EPA inspector how selected raw field survey data is used to 

calculate final surface elevations published in their annual report. 

5.0 Summary of finding, observation, concerns, and recommendations.

 Based on program documents, interviews, and field demonstrations during the inspection, 

EPA concludes that the monitoring program covers the ten monitor parameters required by 

EPA’s 1998 Certification Decision. This inspection determined that the monitoring, sample 

collection, and sample/data analysis procedures were complete and appropriate; that staff were 

adequately trained and implemented the procedures adequately; and that appropriate quality 

assurance measures are applied. For these reasons, EPA finds that DOE has maintained adequate 

parameter monitoring during the past year and has the procedures and requirements in place to 

sustain their program into the next year. EPA has no findings or concerns. 
6 

Attachment A: Inspection Plan and Checklist

2006 Monitoring Parameter Inspection Plan

Purpose: 

Verify that the Department of Energy (DOE) is appropriately monitoring the parameters required 

by EPA’s compliance decisions and approvals. This inspection is conducted under the authority 

of 40 CFR 194, Section 21. 

Scope: 

Inspection activities will include an examination of monitoring and sampling equipment both on 

and off site, and in the underground. A review of sampling procedures and measurement 

techniques may be conducted. Quality assurance procedures and documentation for each of 

these activities will also be reviewed. 

Location: 

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

New Mexico and the surrounding vicinity as needed. 

Duration: 

The EPA expects to complete its inspection in two 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 Date: Week of June 19, 2006. 

Documents Required for Review: 

The documents should include revised version of all documents and procedures submitted during 

past inspections (such as current versions of Delaware Basin Monitoring Annual Report 

DOE/WTS 99-2308 Revision 5, Sept. 2004; and, Hydrological Monitoring: WIPP Groundwater 

Monitoring Program Plan WP 02-1 Revision 6, 3/6/03) and any new materials related to the site 

parameter monitoring program. If there are any questions as to the documents required, please 

contact Chuck Byrum at 214-665-7555. 
Monitoring Commitments – June 2006 Geomechanical Parameters

# Question Comment (Objective Evidence) Result

1 Does DOE demonstrate that they have 

implemented plans/programs/procedures to 

measure - 

a) Creep Closure; 

b) Extent of Deformation; 

c) Initiation of Brittle Deformation and 

d) Displacement of Deformation Features 

during the pre-closure phase of operations as 

specified in the CCA part of the geomechanical 

monitoring system? 

(CCA, Volume 1, Table 7-7; App MON, Table 

MON-1) 40 CFR 194.42 (c) and (e) 

WIPP Geotechnical Engineering Program 

Plan, (WP 07-01: COB-M2006-D), 

documents plans to measure, report, and the 

QA requirements related to these activities. 

Section 3.0 of WP 07-01 documents the 

geomechanical monitoring program and 

records the activities associated with this 

program. Section 4.0 of WP 07-01 

documents the quality assurance 

requirements for these activities. 

During this inspection Ricky Whitely and 

Sam Dominguez demonstrated the adequacy 

of the program and that the program 

produces satisfactory results (COB-M2006-

S10, -S11, -S12, -S13a and -S13b). They 

showed samples remote measurement, 

sample plots, and Ricky Whitely preformed 

underground measurements of convergence 

and rock bolt load cells (COB-M2006-S10 

and -S11). WTS continues, as last year, to 

enhance roof control to mitigate the impact 

of stringers anhydrite stringers in Panels 3 

and 4. 

Results of this program are documented 

annually in the Geotechnical Analysis Report 

for each reporting period (DOE/WIPP 06-

3177: COB-M2006-A and -A2). 

The inspector toured and reviewed the 

computer system and databases used to 

collect and process recorded data. 

SAT 

2 Does DOE demonstrate that they have 

implemented an effective quality assurance 

program for item 1 above? 40 CFR 194.22 

During this inspection the EPA inspector 

evaluated the quality assurance program and 

found it to be adequate. 

SAT 

3 Does DOE demonstrate that the results of the 

geotechnical investigations are reported 

annually? (CCA, App. MON, Page MON-10) 

WP 07-01, Section 3.2 requires that analysis 

be performed annually and results are 

published in the geotechnical analysis report 

(DOE/WIPP 06-3177). 

SAT 

SAT = Satisfactory 

USAT = Unsatisfactory 
Monitoring Commitments – June 2006 Hydrological Parameters

# Question Comment (Objective Evidence) Result

1 Does DOE demonstrate that they have 

implemented plans/programs/procedures to 

measure - 

a) Culebra Groundwater Composition; 

b) Change in Culebra Groundwater Flow 

Direction 

during the pre-closure phase of operations as 

specified in the CCA part of WIPP’s 

groundwater monitoring plan? 

(CCA, Volume 1, Table 7-7; App MON, Table 

MON-1) 40 CFR 194.42 (c) and (e) 

WIPP Groundwater Monitoring Program Plan, 

WP 02-1(COB-M2006-C) documents plans to 

measure, document, report, and the QA 

requirements for these activities. WP 02-1 

records the activities associated with this 

program (Section 4), methods used (Section 5 

and 6), and reporting requirements (Section 8). 

Section 11.0 of WP 02-1 documents quality 

assurance requirements. 

Joel Siegel discussed changes to the program 

over the past year (COB-M2006-S2). Rick 

Salness explained the new “hand” contouring 

techniques used to develop maps used to find 

flow direction in the Culebra (COB-M2006-

S14, -S15a, and –S15b) 

SAT 

2 Does DOE demonstrate that they have 

implemented an effective quality assurance 

program for item 1 above? (CCA, App MON, 

Page MON-22) 40 CFR 194.22 

During this inspection the EPA inspector 

evaluated the quality assurance program and 

found it to be adequate. 

SAT 

3 Does DOE demonstrate that the results of the 

groundwater monitoring program are reported 

annually? (CCA, App. MON, Page MON-22) 

WP 07-01, Chapter 3.2 requires that analysis 

be performed annually and results are 

published in the annual Waste Isolation Pilot 

Plant Site Environmental Report (DOE/WIPP 

05-2225: COB-M2006-O) Chapters 4.3 and 

6.0. 

SAT 

SAT = Satisfactory 

USAT = Unsatisfactory 
Monitoring Commitments – June 2006 Waste Activity Parameters

# Question Comment (Objective Evidence) Result

1 Does DOE demonstrate that they have 

implemented plans/programs/procedures to 

measure - 

a) Waste Activity? 

(CCA, Volume 1, Table 7-7; App MON, Table 

MON-1) 40 CFR 194.42 (c) and (e) 

WIPP Waste Information System Program and 

Data Management Plan (WP 08-NT.01: COBM2006-G, Section 6.0) describes how the 

WWIS is used to measure and store waste 

activity information. WWIS User’s manual 

(Section 9, DOE/CBFO 97-2273: COBM2006-X) documents procedures used to 

gather, store, and process waste activity 

information. Table 3 of the Annual Change 

Report 2004/2005, (DOE/WIPP 05-3317: 

COB-M2006-Z) updates waste activity 

annually. 

WWIS staff demonstrated the use of the 

WWIS and generated numerous reports 

(COB-M2006-S21). Such as the Nuclide 

Report which summaries isotopes emplaced at 

WIPP. These activities demonstrate that 

waste activity is adequately monitored.

SAT

2 Does DOE demonstrate that they have 

implemented an effective quality assurance 

program for item 1? (CCA, App WAP, page 

C-30) 40 CFR 194.22 

During this inspection the EPA inspector 

evaluated the quality assurance program and 

found it to be adequate. 

SAT 

3 Does DOE demonstrate that the results of the 

waste activity parameters are reported 

annually? (CCA Volume, Section 7.2.4 

Reporting) 

WP 08-NT.01 Section 6, page 11 “Regulatory 

Reporting” documents that results are reported 

annually. 

SAT 

SAT = Satisfactory 

USAT = Unsatisfactory 
Monitoring Commitments – June 2006 Drilling Related Parameters

# Question Comment (Objective Evidence) Result

1 Does DOE demonstrate that they have 

implemented plans/programs/procedures to 

measure - 

a) Drilling Rate; and 

b) Probability of Encountering a Castile Brine 

Reservoir? 

(CCA, Volume 1, Table 7-7; App MON, Table 

MON-1) 40 CFR 194.42 (c) and (e) 

The Delaware Basin Drilling Surveillance 

Plan, (WP 02-PC.02: COB-M2006-F), 

documents the program planned to measure, 

document, report, and the QA requirements 

for these activities. Section 6.0 of WP 02-

PC.02 documents quality assurance 

requirements. The Delaware Basin Drilling 

Database Upgrade Process (WP 02-EC3001: 

COB-M2006-R) documents the process used 

to update databases with information from 

various commercial and state sources. 

Drilling rate and Castile brine probability are 

updated annually in the Delaware Basin 

Monitoring Annual Report (DOE/WIPP 99-

2308: COB-M2006-N) in Sections 2.5 and 

2.6. 

Dave Hughes discussed changes during the 

past year (COB-M2006-S1). He reported on 

brine encounters, drilling rate calculations, 

and provided maps of drilling activities near 

WIPP (COB-M2006-S16, -S17, -S18, -S19, -

S20 and -S24). He demonstrated that DOE is 

adequately monitoring these parameters. 

 

SAT 

2 Does DOE demonstrate that they have 

implemented an effective quality assurance 

program for item 1 above? (CCA, App DMP, 

page DMP-9) 40 CFR 194.22 

During this inspection the EPA inspector 

evaluated the quality assurance program and 

found it to be adequate. 

SAT 

3 Does DOE demonstrate that the results of the 

drilling related parameters are reported 

annually? (CCA Volume, Section 7.2.4 

Reporting; App DMP, page DMP-9) 

WP 02-PC.02 Section 6.0 documents that 

results are reported annually. COB-M2006-N 

verifies that these parameters are updated and 

reported annually. 

SAT 

SAT = Satisfactory 

USAT = Unsatisfactory 
Monitoring Commitments – June 2006 Subsidence Measurements

# Question Comment (Objective Evidence) Result

1 Does DOE demonstrate that they have 

implemented plans/programs/procedures to 

measure - 

a) Subsidence measurements? 

(CCA, Volume 1, Table 7-7; App MON, Table 

MON-1) 40 CFR 194.42 (c) and (e) 

WIPP Underground and Surface Surveying 

Program (WP 09-ES.01: COB-M2006-B), 

documents the program used to measure, 

document, report, and the QA requirements 

for these activities. The WIPP Subsidence 

Monument Leveling Survey for 2005 

(DOE/WIPP 06-2293: COB-M2006-E) 

documents that DOE reports this parameter 

annually and the results of this program. 

Ben Zimmerly demonstrated that procedures 

are adequately implemented when he showed 

how the raw field data collected is reduced to 

useful survey and how annual results are 

calculated. They demonstrated that subsidence 

is adequately monitored at the site. 

SAT 

2 Does DOE demonstrate that they have 

implemented an effective quality assurance 

program for item 1? 40 CFR 194.22 

During this inspection the EPA inspector 

evaluated the quality assurance program and 

found it to be adequate. 

SAT 

3 Does DOE demonstrate that the results of the 

subsidence measurements are reported 

annually? (CCA Volume, Section 7.2.4 

Reporting) 

WP 09-ES.01 Section 1.1 documents that 

results are reported annually 

SAT 
Attachment B: Documents Reviewed