### DOCKET NO: A-98-49

Item: II-B3-112



## 2010 - Subpart A Inspection Report

INSPECTION No. EPA-WIPP-6.10-29a

OF THE

WASTE ISOLATION PILOT PLANT June 29 to July 1, 2010

U. S. ENVIRONMENTAL PROTECTION AGENCY

Office of Radiation and Indoor Air Center for Waste Management and Federal Regulation 1200 Pennsylvania Avenue, NW Washington, DC 20460

September 2010

### Table of Contents

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

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

3.0 Inspection Team, Observer s, and Participants .......................................................................... 2

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 annua l inspection of the Department of Energy (DOE) Waste Isolation Pilot Plant (WIPP) June 29 to July 1, 2010 as part of our continued oversight program. This in spection was conducted under the authority of 40 CFR 191, Subpart A. The purpose of this inspecti on was to verify that DOE was in continued compliance with the dose release sta ndard found at 40 CFR 191.03, Subpart A.

EPA reviewed DOE’s ability to monitor radi oactive releases to the public due to normal waste disposal operations and any unplanned or accidental releases that might occur during disposal operations. EPA reexamined DOE’s c ontinued moisture problems and salt loading at the Station A sampling location in the air exha ust shaft. EPA inspectors examined WIPP’s

emission control devices and methods used to estim ate radiation doses to the public. In addition, EPA inspected radiation sample locations and eq uipment, sample processing, and reviewed the computational methods used to estimate dose. EPA observed filter changes, probe pulls, and probe replacement at Station A.

EPA found that DOE continued to improve its air monitoring program during the past year. EPA verified that DOE continues to in crease probe cleaning frequency to weekly as

needed and continued to work toward a solution to this persistent moisture problem at Station A.

DOE continues to have an effective radiati on sampling program because of the continued diligence of site staff and can calculate both yearly and accidental dose estimates adequately. EPA did not have any findings or concerns.

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 continued to focus on the impact of moisture and salt loading on the sampling location at Station A and the effectiveness of the RADOS CAMs used at

the air exhaust of the active waste emplacement panel in the underground.

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

The inspection team consisted of three EPA staff. Thomas Kesterson and Steve Holmes

of the State of New Mexico Environmental De partment observed the inspection. Jerry Fox, Chris Timm, and Greg Huddleston observed the opening meeting pres entations. Claude Magnuson from DOE headquarters also observed the inspection activities.

Inspection Team Member Position Affiliation

Chuck Byrum Inspection Leader EPA

Nick Stone Inspector EPA

Jonathan Walsh Inspector EPA

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

Participant or Observer Participant or Observer

Mike Gross Art Chavez

Randy Elmore Larry Madl

Mansour Akbarzadeh Dave Speed

Jennifer Hendrickson Tom Goff

Dan Ferguson David Squires

4.0 Performance of the Inspection

The inspection began on Tuesday, June 29, 2010, with an opening meeting that included presentations on changes in air monitoring a nd WIPP laboratory activities (COB-M2010-S4 to – S6). Site staff discussed changes in the progr am since the last EPA inspection in July 2009. These presentations included the fo llowing changes to the program:

- Replaced Skid A-3 transport line and probe.

- Procedure PM 364001 (COB-A2010-P2) revised to be more conservative. Set maximum probe pull interval to two weeks.

- Developed prototype of back flush system, wo rking on flush test plan (COB-A2010-S5, Photos COB-A2010-Photo 052 to 056).

- Procedures for both effluent monitoring and la boratory analysis have had minor changes.

### 3 - Installed RADOS CAMs in Panel 6.

- Appeared to have solved filter jamming issue on the RADOS CAMs. Replaced old filter holders and changed training.

-Study by Mike Gross, “Representative of Samples by Shrouded Probes in the Exhaust Shaft at the WIPP”, almost published (COB-A2010-20). Concluded that Station A measures representative samples and recommended that pr obe pull frequency be bi-weekly for Stations A2 and A-3.

- Continued to work on remote access to RADOS CAMs.

The EPA inspector observed va rious activities to verify effective implementation of procedures. EPA reviewed procedures and implem entation of procedures, interviewed site staff,

and observed activities such as filt er changes and probe exchanges.

4.1 Overall Inspection Activities

The inspector observed sample filter change s and shrouded probe pulls at Stations A, examined the weekly shrouded probe changes, reviewed the underg round RADOS CAMs, and examined the processing of samples at the radiochemistry laboratory.

4.2 RADOS CAMs - Filter Transport Problems – Appears Solved.

Last year it was reported that the auto-f ilter changing mechanism jammed periodically when a filter was being changed on the RADOS CAMs located at the air exhaust of Panel 5.

DOE made modifications to the operation of the CA M transport system and placed the two CAMs in a Master/Slave configuration to ensure that the two CAMs did not change filters at the same time. Since last year the old filter holders have been replaced and additional training appears to have solved the jamming problems (COB-M2010-S2)

4.3 Continued Moisture Problems and Salt Buildup at Station A

DOE changed the shrouded probes weekly fo r most of the past year to mitigate the potential impact of salt loading on the probes at Station A. This approach appears to stop probe

failures. DOE has also continue d to study the impacts of humidity, temperature, and air flows to enhance their ability to potential predict probe pull frequency (COB-M2010-S14, -S15, -S17, - S21, and -S22). DOE believes that they have a reasonable approach and has decreased the probe pull frequency to biweekly during the summer months.

Mike Gross (presentation: COB-M2010-S20) did an extensive study of Station A and the causes of moisture buildup and salt loading at Sta tion A. He concluded th at Station A measures representative samples and that , if Station A-2 and A3 are th e locations of record for air sampling, then a biweekly probe pull schedule is adequate.

### 4 During the inspection EPA examined DOE’s activities this y ear (COB-M2010-S17, -S20 to –S22) and determines that DOE and site staff continues to be aggressi ve monitoring Station A probe conditions. EPA also agrees with DOE c onclusion to use biweekly probe changes during

the summer. EPA concurs with Mike Gross’ re commendation if Stations A-2 and A-3 are used as the stations of record that biweekly probe pul l are appropriate and that the approach should be

tested.

DOE provided an update on the probe flush syst em, the system that may be used to clean the shrouded probes in place, without removal. The prototype has been built (photos COBM2010-Photos 052 to 056) and the site is develo ping a test plan (COB-M2010-S4) to evaluate its performance. EPA continues to be skeptical that the flush system will work in the exhaust shaft

environment but looks forward to DOE’s test results.

EPA also toured the laboratory that s upports annual NESHAP reporting and emergency response activities at WIPP. EPA verified that the laboratory continue s to adequately support WIPP’s needs (COB-M2010-S30 and Photos 173 to 184) . EPA also questioned if site staff are qualified to perform manual (hand) release calc ulations if all other systems fail during an emergency. Site staff notes that all radiation technicians must show pr oficiency in performing manual calculations to become qualified and th at the steps of the hand calculations are documented in WP 12-ER4916, Section 3.0 (COB-M 2010-P). Staff also provided an example (COB-M2010-S16) of a manual release calculation.

5.0 Summary of Findings

EPA concludes that DOE continues to ade quately implement a radiological monitoring and sampling program for WIPP disposal operations and appropriately performs calculations to estimate potential releases to the public. EP A does not have any fi ndings or concerns.

### 5 Attachment A: Inspection Plan and Checklist



## WIPP Inspection Plan - 40 CFR 191, Subpart A for the year 2010
Purpose : EPA will verify that the Department of Ener gy (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 la st reporting period. This inspection is conducted under the authority of 40 CFR 191, Subpart A. This inspection is part of EPA’s continued oversight to ensure that WIPP can, during the op erational phase of mana gement and storage of radioactive waste, comply with th e limits expressed in 40 CFR 191.03.

Scope : The scope of this inspection activity is to veri fy that DOE at WIPP can measure and calculate and has measured and calculated any actual or pot ential radiation dose to members of the public during management and storage of radioactive wa ste during the past year of site operation. Inspection activities will include an examination of the description of monitoring and sampling equipment both on and off site, and in the underground.

The specific purpose of this inspection is to ve rify and confirm that DOE at WIPP has complied with the “Compliance reporting” exp ectations of EPA GUIDANCE FOR THE

IMPLEMENTATION OF EPA’s STANDARDS FOR MANAGEMENT AND STORAGE OF TRANSURANIC WASTE (40 CFR Part 191, Subpart A) at the WASTE ISOLATION PILOT

PLANT (402-R-97-001), Section 4.2, Page 15. In part icular the EPA wishes to verify that DOE complies with the Subpart A standard is demons trated by showing that the annual radiation dose to any member of the public in the genera l environment falls below the regulatory limits.

Focal Areas for this Years Inspection:

# What has changed in air sampling si nce last year’s inspection?

# During past years a number of potential change s were discussed, such as new methods to evaluate salt build-up on Station A probes. What is the status of these activities?

# With continued moisture in the exhaust shaft ai r flow, what have been the conditions of the sample filters? Have the filters had salt bu ildup or samples washed off as in the past?

# Verify that the underground CAMs operate as expected.

# Station A continues to have challenging salt buildup. A pro cedure has been developed by the site that is used to predict probe pu ll/cleaning frequency. Describe how this procedure was developed and specifically how it will be implemented. What testing has been done to verify the accuracy of this procedure?

# How are composite samples handled and processed, measurement accuracy, and implications of laborat ory standards used?

# With the continued challenge of salt buildup at Station A, has testing been done to fully qualify the Shrouded Probe under these conditions as required by EPA’s approval letter?

# Provide a presentation of the process and pro cedures used to calculate off-normal potential release during operations, use flow charts, pho tographs, etc as needed. Provide examples of various accidental scenarios with appropr iate calculations-source term estimates, etc.

### 6 Describe the process from st art to finish, the steps ta ken to respond to off-normal

situations?

# Bottom-line: If required, how would DOE prove to independent examiners that samples

taken at Station A are re presentative samples?

Location : This inspection will be held at the WIPP f acility located twenty-six miles south east of Carlsbad, New Mexico and the surrounding vicinity as needed.

Duration : The EPA expects to complete its inspection in three days. Each day will begin with an opening meeting at 8:00 a.m. and end before 5:00 p.m. with a closeout session.

Expected Dates : Week of June 28, 2010.

Information Requested: Before the inspection, provide the most recent annual Safety Analysis Report, information that describes how measur ements are taken and complete documentation that shows how compliance calculations are pe rformed with an explanation of all input parameters and their derivation a nd all pertinent related to Subpa rt A requirements. Provide documentation and procedures related to subpart Subpart A compliance ac tivities as in past

years.

### 7 # CHECKLIST QUESTION June 2010 40 CFR 191.03 Subpart A

Sat. = Satisfactory NA = Not Applicable

40 CFR 191.03 Compliance Standard EPA Citation Comment (Object ive 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 radioac tive material and direct radiation from such management and storage and (2) all operations covered by Pa rt 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 for 2008 (DOE/WIPP 09-2225:COB-A2010-C) Executive Summary documents the results of DOE’s efforts to

consider all activities th at impact compliance.

Section 4.9 demonstrates that measured releases are well below the 40 CFR 191.03(b) release standards for a member of the public residing year round at the

fence line. 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 Implem entation Plan for Subpart A (DOE/WIPP 00-3121:COB-A2010-A), documents the plan to show how this requirement is examined. QAPP for Sampling Emissions (WP 12- RC.01:COB-A2010-F), documents the QA requirements for the sampling of emissions. Annual NESHAP report (COB-A2010-Ja,-Jb,-Jc)

demonstrates that normal operations are examined. CH Waste Documented Safety Analysis (DOE/WIPP 95-2065:COB-A2008-G) and RH Waste DSA (DOE/WIPP 06-3174:COB-A2008-H) documents DOE’s review of potential accidents at WIPP. Procedure Emergenc y Radiological Control Response (WP 12-HP4000:COB-A2010-K) and Consequence Assessment Dose Projection (WP 12- ER4916:COB-A2010-R) 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 09-2225 pages xxii, Dose From Air Emission, and Chapter 4 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 DOE/WIPP 09-2225, Section 4.8.4 and 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-A2010-Ja,-Jb,-Jc) demonstrates that these exposure mechanisms are

included. Sat.

### 8 # CHECKLIST QUESTION June 2010 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-A2010-A) explains DOE’s plan to fulfill this requirement. Annual Site Environmental Report (DOE/WIPP 09-2225:COB-A2010-C) Chapter 4 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 For Subpart A DOE (DOE/WIPP 09- 2225, Section 4.8.4.3) assumes that themember of the public resides, “... yearround at the fence line in the northwest sector.” DOE/WIPP 09-2225, Section 1.3.2, page 30 and the Annual NESHAP report (COB-A2010-Jb page 6 and -Jc page 1) 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 For Subpart A DOE (DOE/WIPP 09-2225, page xxiv) assumes that the member of the public resides, “... year-round at the fence

line in the northwest sector.” DOE/WIPP 00-3121 page 30 and the Annual NESHAP report (COB-A2010-Jb, page 6)

demonstrate that DOE considers doses at appropriate offsite points, such as Smith Ranch located 7.5 km away in the NW

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 For Subpart A DOE (DOE/WIPP 08-2225, Section 4.8.4.3) assumes that the member of the public resides, “... year-round at the

fence line in the northwest sector.”

DOE/WIPP 08-2225:COB-A2010-C

Section 1.3.2 and the Annual NESHAP report (COB-A2010-Jb, page 6)

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 # CHECKLIST QUESTION June 2010 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-A2010-A) describes the “reference man” parameters as described in the CAP88-PC computer code. Annual NESHAP report (COB-A2010-Jc 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 cri tical organ radiation dose for the maximally exposed individual (or a hypothetical indi vidual conservatively located at a point of higher exposure)? EPA 402-R-97-001 Section 2.7.1, Page

8 Annual NESHAP report (COBA2010-Jc, page 1) 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 to confirm the air pathway. Annual NESHAP report (COB-A2010- Jb) 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 mode l will be used to

calculate radiat ion doses. Annual NESHAP report 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 DOE/WIPP 09-2225, page xxiv and

Section 3.2 of DOE/WIPP 00-3121 states

that CAP88-PC is used for dose calculations. Annual NESHAP report 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 DOE uses a atmospheric dispersion code (HOTSPOT) to determine concentrations

for accidental releases. WP 12-ER4916 (COB-A2010-R) states that HOTSPOT is

used for accidental release calculations. COB-A2010-S11 shows an example of dose projection using the HOTSPOT

code. HOTSPOT 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 repor t demonstrates that DOE is using appropriate parameters

in dose calc ulations. Sat.

### 10 # CHECKLIST QUESTION June 2010 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 Section 3.2 of DOE-WIPP 00-3121 (COB-A2010-A) documents that DOE is using conservative assumptions. Annual NESHAP report (COB-A2010-Jb,-Jc) 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-A2010-A) states that DOE is using these values as exposure parameters. The Annual NESHAP report (COB-A2010-Jc, page 25) demonstrates that DOE is using these parameters in dose

calculations Sat.

### 11 # CHECKLIST QUESTION June 2010 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-A2010-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:COBA2010-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 4.2 and

Attachment 1 the location of sampling sites. Sat.

### 12 # CHECKLIST QUESTION June 2010 40 CFR 191.03 Subpart A

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

23a 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 monito ring, 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. The Implementati on Plan for Subpart A (DOE/WIPP 00-3121:COB-A2010-A)

Section 3.3.3 states th at DOE uses periodic confirmatory monitoring. DOE/WIPP 00-

3121 Sections 3.5 and 3.3.5 document

relevant radionuclides at WIPP. Annual NESHAP report (COB-A2010-Jc)

demonstrates that these radionuclides are

monitored. NA

23b 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-A2010-1)

Section 5.2.1 and DOE/WIPP 00-

3121:COB-A2010-A Section 3.3 states that sample sites will acquire representative samples. 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-A2 010-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 guid ance 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 withShrouded Probes (LA-12612-MS:COBA2006-4) documents how the shrouded probe was qualified for use at WIPP. Sat.

### 13 # CHECKLIST QUESTION June 2010 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-A2010-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-A2010-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 underes timate 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 usesSection 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:COBA2010-B) discusse s release points measured confirm compliance with this requirement. Sat.

### 14 # CHECKLIST QUESTION June 2010 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-A2006-3) 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 veri fy 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:COBA2010-G) and RH (DOE/WIPP06-3174:COB-A2010-H) 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-A2010-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 5.2.1 of the WIPP Environmental Monitoring Plan (DOE/WPP 99-2194:COB-A2010- 1) states: “Station A exhausts unfiltered air from the underground repository to the atmosphere. Station B samples HEPA filtered exhaust air from the underground repository to the atmosphere when in Filtration Mode of operation. Station C samples HEPA filtered

exhaust 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.

### 15 # CHECKLIST QUESTION June 2010 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

### 16 # CHECKLIST QUESTION June 2010 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:COBA2010-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 08-2225:COB-A2010-C) Chapter 4

demonstrates that DOE’s environmental program monitors other release points and critical receptor locations. Sat.

### 17 # CHECKLIST QUESTION June 2010 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-A2010-A) documents that DOE’s plans to report results yearly. The Annual NESHAP (COB-A2010- Ja,-Jb,-Jc) report demonstrates that DOE reports results yearly and “...fall below regulatory limits”. 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

annual 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 construc tion 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. TheAnnual NESHAP Report (COBA2010-Jb page 7) demonstrates that DOE reports planned

construction and modification during the year. Sat.

45 Does DOE demonstrate that advanced

notification was not ne eded 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-A2010-A documents that DOE’s plans to report results yearly. The Annual NESHAP Report (COB-A2010-Jb page 7), demonstrates that DOE reports planned construction and modification during the year. 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.

### 18 Attachment B

Table of Documents ReviewedDocuments Reviewed and Copies ReceivedDuring Inspection191.03 Subpart A Inspection July 2010 DOE Documents**ID#**Document TitleSubject MatterSource**EPA 402-R-97-001 Guidance For The Implementation of EPA's Standards For Management And Storage of Transuranic Waste (40 CFR** **Part 191, Subpart A) at the Waste Isolation Pilot Plant EPA 402-R-97-001, January 1997** **"WIPP Subpart A Guidance" EPA COB-A2010-1 Waste Isolation Pilot Plant Environmental Monitoring** **Plan. DOE/WIPP 99-2194. Rev 4, 11/08. In particular Section 4.0 and 5.0.** **Discussed DOE environmental monitoring plans at the WIPP site.** **DOE/WIPP COB-A2006-2 Memorandum of understanding between EPA and DOE,** **September 29, 1994 Agreement states that DOE will implement NESHAPs** **regulations at the WIPP site. DOE/WIPP** **COB-A2006-3 EPA Shrouded Probe Approval Letter, November 10, 1994 Allows DOE to use the shrouded probe as an alternative measuring procedure.** **DOE/WIPP COB-A2006-4 Single-Point Representative Sampling with Shrouded** **Probes by McFarland and Rodgers, LA-12612-MS, August 1993** **Describes shrouded probe testing requirements and test performed to qualify probe for use at WIPP.** **DOE OSTI Document website.** **COB-A2010-A Implementation Plan for 40 CFR 191, Subpart A DOE/WIPP 00-3121, Revision 3, January 2010** **Outlines program at WIPP to show compliance with 40 CFR 191, Subpart A.** **DOE/WIPP COB-A2010-B** **Periodic Confirmatory Measurement Protocol for the Waste Isolation Pilot Plant, DOE/WIPP 97-2238, Revision 8,** **August 2008 Used to explain the protocol used to perform periodic** **confirmatory measurements. DOE/WIPP** **COB-A2010-C Waste Isolation Pilot Plant Annual Site Environmental Report for 2008, DOE/WIPP 09-2225, 0909** **Results of the environmental monitoring program, in particular radiological measurements.** **DOE/WIPP COB-A2010-D Airborne Radioactivity - Technical Procedure** **WP 12-HP3500, Revision 18, 05/07/10 Procedure provides instructions for analyzing, reporting, and** **trending results of air samples. DOE/WIPP** **COB-A2010-E WIPP Quality Assurance Program Description WP 13-1, Revision 29, 05/10/10** **Minimum quality requirements for WIPP. DOE/WIPP COB-A2010-F Quality Assurance Program Plan for Sampling Emissions** **of Radionuclides to the Ambient Air at the Waste Isolation Pilot Plant, WP 12-RC.01, Revision 9, 04/26/10** **QA program for sampling air emissions at WIPP. DOE/WIPP** **COB-A2008-G WIPP CH Waste Documented Safety Analysis, Section 3.4.1.4. DOE/WIPP-95-2065 Rev. 10, 11/06** **This selection verifies that the air pathway is the only pathway of concern at the WIPP for CH waste.** **DOE/WIPP.**Documents Reviewed and Copies ReceivedDuring Inspection191.03 Subpart A Inspection July 2010 DOE Documents**ID#**Document TitleSubject MatterSource**COB-A2008-H WIPP RH Waste Documented Safety Analysis, Section 3.4.1.4. DOE/WIPP-06-3174 Rev 0, 03/06** **This selection verifies that the air pathway is the only pathway of concern at the WIPP for RH waste.** **DOE/WIPP. COB-A2010-I Periodic Confirmatory Sampling, Reporting, and** **Compliance Activities, Management Control Procedure, WP 12-RE3004, Rev 3, 11/12/09** **This procedure provides instructions for Radiological Engineers of the Radiological Controls Department to fulfill** **the requirements of NESHAPs. DOE/WIPP** **COB-A2010-Ja,-Jb - Jc** **Annual Periodic Confirmatory Measurement Compliance Report for the DOE WIPP and CAP88-PC Version 2.00** **Output File for CY-2009 WIPP Annual NESHAP Report. 06/22/2010** **Documents annual results. DOE/WIPP COB-A2010-K Emergency Radiological Control Responses, Emergency** **and Alarm Response Procedure, WP 12-HP4000, Revision 6, 05/27/10** **Section 3.0 documents actions to be taken in the event of and “ON-SITE AIRBORNE RADIOACTIVITY EVENT”.** **DOE/WIPP COB-A2010-AK Fixed Air Monitoring Equipment, Technical Procedure** **WP 12-HP1305, Revision 8, 05/07/10 Instructions for the operation of fixed air monitoring** **equipment. Attachment 2 documents flow rates and alarm set points.** **DOE/WIPP COB-A2010-AL** **Canberra Alpha Sentry Continuous Air Monitor, Technical Procedure WP 12-HP1306, Revision 7, 11/11/09** **Instructions for operating the Canberra continuous air monitor equipment.** **DOE/WIPP COB-A2010-AM Portable Instrument and Portal Monitor Operability** **Checks, Technical Procedure, WP 12-HP1307, Revision 10, 05/14/09** **Instructions for operational checks of portable contamination instruments.** **DOE/WIPP COB-A2010-AN2 Portable Alpha-6 Continuous Air Monitors, Technical** **Procedure WP 12-HP1308, Revision 3, 07/16/08 Instructions for operation of Portable Alpha-6 continuous air** **monitor. DOE/WIPP** **COB-A2010-AO Radiological Event Response, Emergency Response Procedure, WP 12-ER4903, Revision 13, 02/27/09** **Procedure documents actions taken if a potential or actual radioactive release takes place.** **DOE/WIPP COB-A2010-AP Radiological Event Reporting, Management Control** **Procedure WP 12-HP3700, Revision 3, 10/29/08 Documents the ‘first’ estimate of a possible release.** **DOE/WIPP COB-A2010-L Calibration of Effluent Monitoring Skids A1, A2, A3, B1** **and B2 Flow Instrumentation, Maintenance Procedure, IC041072, Revision 9** **Instructions for calibration of FAS skids A1, A2, A3, B1 and B2 flow instrumentation.** **DOE/WIPP COB-A2010-M Calibration of Station C Flow Instrumentation,** **Maintenance Procedure IC041097, Revision 2 Instructions for calibration of Station C flow** **instrumentation. DOE/WIPP** Documents Reviewed and Copies ReceivedDuring Inspection191.03 Subpart A Inspection July 2010 DOE Documents**ID#**Document TitleSubject MatterSource**COB-A2010-N U/G Exhaust Mass Flow Measurement System for Fans 700A, B & C, Maintenance Procedure, IC041098, Revision** **5 Documents calibration verification test and alignment of** **U/G exhaust. DOE/WIPP** **COB-A2010-O Station B Mass Flow Measurement System, Loop 41A001W2001, Maintenance Procedure, IC413000,** **Revision 5 Documents calibration of Station B mass flow measurement** **system. DOE/WIPP** **COB-A2010-P Inspection and Cleaning of Station “A” Sample Probes Bldg. 364, Maintenance Procedure, PM364005,** **Revision 10 Documents steps to inspect and clean Station A probes.** **Section 8.3 notes that salt buildup "at the probe inlet should be no more than 2/3 of the area" and "blocking the shroud** **exhaust should be limited to no more than 1/3 of that area". DOE/WIPP** **COB-A2010-P2 Predictive Maintenance to Determine Station A Probe Pull Frequency, Maintenance Procedure PM364001, Revision 1** **Determine recommended frequency of Station A probe inspections based on meteorological data.** **DOE/WIPP COB-A2010-P3 Calibration of Station C Mass Flow, Maintenance** **Procedure, IC041096, Revision 4 Perform calibration check of the mass flow instrumentation. DOE/WIPP** **COB-A2010-P4 Inspection and Maintenance of Station "B" Radiation Sample Probes 365-S100 & 365-S-102, Maintenance** **Procedure, PM365001, Revision 4 Instructions for the biennal inspection and maintenance of** **Station B sample probes. DOE/WIPP** **COB-A2010-Q WIPP ALARA Program Manual, WP 12-2, Revision 15, 06/03/10** **Describes organization and responsibilities of ALARA committee and coordinator.** **DOE/WIPP COB-A2010-R Consequence Assessment Dose Projection, Technical** **Procedure WP 12-ER4916, Revision 15, 11/16/09 Documents procedure for estimating the potential dose** **consequence from a release or suspected release of radioactive material.** **DOE/WIPP COB-A2010-Rb Consequence Assessment Dose Projection, Technical** **Procedure WP 12-ER4916, Revision 13, 06/24/09 Documents procedure for estimating the potential dose** **consequence from a release or suspected release of radioactive material.** **DOE/WIPP COB-A2010-AQ Radiological Engineering Off-site Air Sampling -** **Technical Procedure WP 12-RE3002, Revision 2, 04/09/10 Instructions for collecting and documenting Low-Volume** **filter retrieval in response to a potential release. DOE/WIPP** Documents Reviewed and Copies ReceivedDuring Inspection191.03 Subpart A Inspection July 2010 DOE Documents**ID#**Document TitleSubject MatterSource**COB-A2010-AR Radiological Release of Potentially Contaminated Materials, Waste, and Items - Management Control** **Procedure, WP 12-RE3003, Revision 4, 10/27/09 Instructions for evaluating materials, waste, and items which** **are to be released from the WIPP as non-radioactive material.** **DOE/WIPP COB-A2006-ZA** **Air Sampling With Shrouded Probes At The WIPP Site, by McFarland, Sept 1993** **Paper discussing the use of the shrouded probe at WIPP. Benefits of the shrouded probe are discussed.** **DOE/WIPP COB-A2006-ZB Effects of Salt Loading and Flow Blockage on the WIPP** **Shrouded Probe, by Chandra, Ortiz, McFarland, August 1993, DOE/WIPP 93-043** **Report discusses the impact of salt loading on shrouded probe performance.** **DOE/WIPP COB-A2006-ZC Evaluation Of The Station B Effluent Monitoring System** **In The Underground Exhaust Ventilation System At The WIPP, Sept 1990, DOE/WIPP 89-027** **Documents testing at WIPP to evaluate the ability of Station B to collect representative samples.** **DOE/WIPP COB-A2006-ZD Evaluation of the Station C Effluent Monitoring System In** **The Waste Handling Building Ventilation System At The WIPP, Dec 1989, DOE/WIPP 89-028** **Documents testing at WIPP to evaluate the ability of Station C to collect representative samples.** **DOE/WIPP COB-A2006-ZE The Influence of Salt Aerosol On Alpha Radiation** **Detection By WIPP Continuous Air Monitors, by Bartlett and Walker, Jan 1996, EEG-60, DOE/AL/58309-60** **Reports impact of salt deposits on monitor efficiency. DOE/WIPP COB-A2006-ZF Evaluation Of The Station A Effluent Monitoring System** **In The Underground Exhaust Ventilation System At The WIPP, DOE/WIPP 89-026, Sept 1990** **Documents testing at WIPP to evaluate the ability of Station A to collect representative samples.** **DOE/WIPP COB-A2006-ZG Single Point Aerosol Sampling: Evaluation of Mixing and** **Probe Performance In A Nuclear Stack, by Rodgers, Fairchild, Wood, Ortiz, Muyshondt, McFarland, July 1994** **Compares performance of ANSI isokinetic with shrouded probes at DOE faculties.** **DOE/WIPP COB-A2006-ZH Generic Air Sampler Probe Test, by Glissmeyer and** **Ligotke, Nov 1995, PNL-10816 Test of isokinetic and shrouded probes at Hanford. Tests** **show that shrouded probes deliver samples with significantly less particle-size bias.** **DOE/WIPP COB-A2006-ZI Functional Requirements Document For Measuring** **Emissions Of Airborne Radioactive Materials, by Glissmeyer, Alvarez, Hoover, McFarland, Newton,** **Rodgers, Nov 1994, PNL-10148 States general functional requirements for system and** **procedures for measuring emissions. DOE/WIPP** Documents Reviewed and Copies ReceivedDuring Inspection191.03 Subpart A Inspection July 2010 DOE Documents**ID#**Document TitleSubject MatterSource**COB-A2006-ZJ Changing Methodology For Measuring Airborne Radioactivity Discharges From Nuclear Facilities, by** **Glissmeyer and Ligotke, May 1995, PNL-SA-25532 Tests show single-point sampling (shrouded) probes are** **superior to ANSI style multiple-point probes. DOE/WIPP** **COB-A2010-S Radiochemistry Quality Assurance Plan, 12-RL.01, Revision 16, 02/18/09** **Describes the management policy and organizational structure, and QA requirement for radiochemical analysis.** **DOE/WIPP COB-A2010-T Sample Tracking and Custody, Technical Procedure, WP** **12-RL1001, Revision 9, 02/11/09 Instructions for documenting receipt and storage of samples** **in WIPP laboratory. DOE/WIPP** **COB-A2010-U Alpha Spectroscopy System Operation, Technical Procedure, WP 12-RL1002, Revision 9, 10/05/09** **Direction for calibrating and operating the Canberra Alpha Spectroscopy System as interfaced with the Genie 2000.** **DOE/WIPP COB-A2010-V Establishing Gross Alpha and Gross Beta Self-Absorption** **Curves, Technical Procedure, WP 12-RL1008, Revision 7, 11/17/09** **Instructions for preparing samples of known activity and known weight to generate self-absorption curves for each of** **the gas proportional counters. DOE/WIPP** **COB-A2010-W Gross Alpha and Gross Beta Activity in Air Filter, Soil, Water, Sludge, and Biota, Technical Procedure, WP 12-** **RL1009, Revision 4, 10/22/07 Guidance for rapidly performing a variety of screening** **matrices for both high and low activity Radionuclides. DOE/WIPP** **COB-A2010-X Sample Preparation, Technical Procedure, WP 12-RL1010,** **Revision 9, 11/05/08 Directions for preparing samples to determine activity of** **Radionuclides. DOE/WIPP** **COB-A2010-Z Elemental Separation - Strontium 90, Technical Procedure,** **WP 12-RL1011, Revision 11, 09/13/07 Directions for performing elemental separation of strontium** **from samples. DOE/WIPP** **COB-A2010-AA Elemental Separation - Transuranic Products, Technical Procedure, WP 12-RL1012, Revision 8, 10/31/06** **Describes method for elemental separation and purification of actinide isotopes in samples.** **DOE/WIPP COB-A2010-AB Sample Mounting, Technical Procedure, WP 12-RL1013,** **Revision 7, 09/12/07 Directions for electrodeposition sample mounting and** **neodymium fluoride coprecipitation sample mounting of actinides in preparation for alpha spectroscopy counting.** **DOE/WIPP COB-A2010-AC Routine Laboratory Operations, Technical Procedure, WP** **12-RL1014, Revision 6, 11/05/08 Instructions for routine laboratory operation. DOE/WIPP** **COB-A2010-AD Canberra Alpha Analyst System Operation, Technical Procedure, WP 12-RL1015, Revision 15, 10/23/09** **Directions for calibrating and operating the Canberra Alpha Analyst 32-chamber alpha spectroscopy system.** **DOE/WIPP**Documents Reviewed and Copies ReceivedDuring Inspection191.03 Subpart A Inspection July 2010 DOE Documents**ID#**Document TitleSubject MatterSource**COB-A2010-AE Operation of the Oxford Series 5 Gas Proportional Counter, Technical Procedure, WP 12-RL1016, Revision** **10, 09/23/09 Guidance for the operation of the Oxford Series 5 Gas** **Proportional Counter. DOE/WIPP** **COB-A2010-AF Plutonium-241 Analysis, Technical Procedure, WP 12- RL1200, Revision 0, 11/26/03** **Provides method for the analysis of Pu 241 in any matrix after preparation of the sample in accordance with WP 12-** **RL1012 and WP 12-RL1015. DOE/WIPP** **COB-A2010-AG Radiochemistry Laboratory Waste Management, Technical Procedure, WP 12-RL1400, Revision 9, 04/02/09** **Instructions for handling, management, and disposal of laboratory waste.** **DOE/WIPP COB-A2010-AH Radiochemistry Laboratory Data Validation and** **Verification, Technical Procedure, WP 12-RL3002, Revision 7, 11/17/09** **Instructions for performing radiochemistry analytical data verification and validation by radiochemistry staff.** **DOE/WIPP COB-A2010-AI Data Reduction and Reporting, Technical Procedure, WP** **12-RL3003, Revision 7, 02/02/09 Instructions for processing laboratory data from the time of** **sample receipt to the reporting of final results. DOE/WIPP** **COB-A2010-AS Property Material Release Evaluation Form, EA12 RE3003-** **1-0, Rev 2, 10/27/09 Material release evaluation form. DOE/WIPP** **COB-A2010-AT Airborne Particulate Sampling, WP12-EM1012, Rev 9, 06/07/07** **Provides steps for environmental monitor personnel to collect and document results.** **DOE/WIPP COB-A2010-AU WIPP Radiation Safety Manual, WP12-5, Rev 13, 05/20/10 States radiological control policy and practices. DOE/WIPP** **COB-A2010-AW Abnormal Radiological Conditions, WP12-HP2001, Rev 4, 06/24/09** **Instructions for radiological control technicians when responding to abnormal conditions.** **DOE/WIPP COB-A2010-AX Radiological Control Administration, WP12-HP3000, Rev** **14, 12/07/09 Instructions for performing radiological control. DOE/WIPP** **COB-A2010-AY Radioactive Material Control, WP12-HP3200, Rev 11, 11/11/09** **Instructions for controlling radioactive items DOE/WIPP COB-A2010-AZ Radiation Exposure Control, WP12-HP3300, Rev 2,** **08/17/05 Guidance for keeping radiation exposure ALARA. DOE/WIPP** **COB-A2010-BA Contamination Control, WP12-HP3400, Rev 8, 02/20/09 Guidance for keeping engineering and administrative controls.** **DOE/WIPP**Documents Reviewed and Copies ReceivedDuring Inspection191.03 Subpart A Inspection July 2010 DOE Documents**ID#**Document TitleSubject MatterSource**COB-A2010-AJ Control of Radioactive Standards, Technical Procedure, WP 12-RL1550, Revision 11, 10/22/09** **Instructions for labeling, maintaining inventory, dilution of standards, completing standard logbook for new standards** **received, expired standards, depleted standards, and recertification or standards.** **DOE/WIPP COB-M2010-ZZ Compliance Monitoring Implementation Plan for 40 CFR** **194.14(b), Assurance Requirement, DOE/WIPP 99-3119, Rev 6, 05/10** **Outlines monitoring activities at WIPP to demonstrate compliance with 40 CFR 191 and 40 CFR 194.** **DOE/WIPP**Documents Received During Inspection**COB-M2010-S1 2010 Inspection Agenda and sign-in sheets for opening and close-out meetings.** **DOE/WIPP COB-M2010-S2 to** **S12 Presentation slides from the inspection opening meeting** **for drilling, hydrology, geotechnical, WWIS topics, etc DOE/WIPP** **COB-M2010-S26 Geomechanical field measurement data sheets, input sheets, plots, and check prints.** **Geomechanical manual convergence measurements at 18613/W170-S3080, remote extensometer measurements at** **51X-GE-00405 (at W520-S2915), Joint Meter (S1950- E0300), Rock Bolt Load Cell (E140-S2916), and Earth** **Pressure Cells (Waste Shaft-Level 866'). DOE/WIPP** **COB-M2010-S24 Subsidence calculations DIGILEV 10.94d field data, raw conversion data, and adjusted elevations from files L0136510** **DOE/WIPP COB-M2010-S34 DBM-55-2010, 2010 map of oil and gas wells in the nine** **township area. DOE/WIPP** **COB-M2010-S35 and -S36** **Map of oil and gas wells within one mile of WIPP boundary** **DOE/WIPP COB-M2010-S37a** **and -S37b List of oil and gas wells in New Mexico (-S37b) and Texas** **(-S39a) DOE/WIPP** **COB-M2010-S31 and -S33** **07/01/2010 Nuclide Reports from the WDS (WWIS replacement).** **DOE/WIPP COB-M2010-S32** **WDS-Summary if Waste Emplacment Inventory Report for 07/01/2010.** **DOE/WIPP COB-M2010-S37** **Materials Emplaced in WIPP as of June 30, 2010**Documents Reviewed and Copies ReceivedDuring Inspection191.03 Subpart A Inspection July 2010 DOE Documents**ID#**Document TitleSubject MatterSource**COB-M2010-Photos 1 to 184** **2010 Annual Inspection Photographs Photographs of underground manual convergence measurements.** **DOE/WIPP COB-E2010-S13 RH Container ID Number and Shipment Summary Report** **DOE/WIPP COB-A2010-S14** **and S15 Wet Filter Efficiency** **DOE/WIPP COB-A2010-S16 WIPP Offsite Potential Release Calculations** **DOE/WIPP COB-A2010-S17 A1, A2, A3 Psychometric and % Tip Occlusion** **DOE/WIPP COB-M2010-S18 Culebra Freashwater Head Modeling and Flow Direction** **DOE/WIPP COB-M2010-S19 Basic Data Report for Well Plugging and Abandonment** **Activities for Fical Year 2009, DOE/WIPP-10-3326, June 2010** **DOE/WIPP COB-A2010-S20 Representativeness of Sampling by the Shrouded Probes at** **Station A in the Exhaust Shaft at WIPP, June 2010, by M. Gross** **DOE/WIPP COB-A2010-S21 Probe Occlusion at Station A-1, June 2007 to June 2010,** **comparison to A-2 and A-3 and photos of probes. DOE/WIPP** **COB-A2010-S22 Humidity, temperature and pressure at Station A weather station, air flow at CAM-151, DP and flow at FAS011,** **FAS0021, FAS0022. DOE/WIPP** **COB-E2010-S23 Panel 5 Room 4 Status Reports** **COB-M2010-S25 Panel 6, Room 2 Geologic Log DOE/WIPP** **COB-M2010-S27 E-140 Fracture Mapping Photos DOE/WIPP** **COB-M2010-S28 East-140 Roof Fracture Plots and Panel 6, Room 1 and Panel 5, Room 1 Spall Maps** **DOE/WIPP COB-M2010-S29 Panel 6 Room 1 Stratigraphy** **DOE/WIPP COB-A2010-S30 NESHAPs Air Filter Laboratory Report, 5 Parts** **DOE/WIPP**