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, Observers, 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 annual 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 inspection was conducted under the authority of 40 

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

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

 EPA reviewed DOE’s ability to monitor radioactive 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 continued moisture problems and salt loading at 

the Station A sampling location in the air exhaust shaft. EPA inspectors examined WIPP’s 

emission control devices and methods used to estimate radiation doses to the public. In addition, 

EPA inspected radiation sample locations and equipment, sample processing, and reviewed the 

computational methods used to estimate dose. EPA 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 increase 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 radiation 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 Department observed the inspection. Jerry Fox, 

Chris Timm, and Greg Huddleston observed the opening meeting presentations. 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 and WIPP laboratory activities (COB-M2010-S4 to –

S6). Site staff discussed changes in the program since the last EPA inspection in July 2009. 

These presentations included the following 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, working on flush test plan (COB-A2010-S5, Photos 

COB-A2010-Photo 052 to 056). 

- Procedures for both effluent monitoring and laboratory 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 probe pull frequency be bi-weekly for Stations A2 and A-3. 

- Continued to work on remote access to RADOS CAMs. 

The EPA inspector observed various activities to verify effective implementation of 

procedures. EPA reviewed procedures and implementation of procedures, interviewed site staff, 

and observed activities such as filter changes and probe exchanges. 

4.1 Overall Inspection Activities 

 The inspector observed sample filter changes and shrouded probe pulls at Stations A, 

examined the weekly shrouded probe changes, reviewed the underground 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-filter 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 CAM 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 for 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 continued 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 Station A. He concluded that Station A measures 

representative samples and that, if Station A-2 and A3 are the locations of record for air 

sampling, then a biweekly probe pull schedule is adequate. 
4

 During the inspection EPA examined DOE’s activities this year (COB-M2010-S17, -S20 

to –S22) and determines that DOE and site staff continues to be aggressive monitoring Station A 

probe conditions. EPA also agrees with DOE conclusion to use biweekly probe changes during 

the summer. EPA concurs with Mike Gross’ recommendation if Stations A-2 and A-3 are used 

as the stations of record that biweekly probe pull are appropriate and that the approach should be 

tested. 

 DOE provided an update on the probe flush system, 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 developing 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 supports annual NESHAP reporting and emergency 

response activities at WIPP. EPA verified that the laboratory continues 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 calculations if all other systems fail during an 

emergency. Site staff notes that all radiation technicians must show proficiency in performing 

manual calculations to become qualified and that the steps of the hand calculations are 

documented in WP 12-ER4916, Section 3.0 (COB-M2010-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 adequately implement a radiological monitoring 

and sampling program for WIPP disposal operations and appropriately performs calculations to 

estimate potential releases to the public. EPA does not have any findings 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 Energy (DOE) has been monitoring and calculating 

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

releases which may have occurred during the last reporting period. This inspection is 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 operational phase of management and storage of 

radioactive waste, comply with the limits expressed in 40 CFR 191.03. 

Scope: 

The scope of this inspection activity is to verify that DOE at WIPP can measure and calculate 

and has measured and calculated any actual or potential radiation dose to members of the public 

during management and storage of radioactive waste 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 verify and confirm that DOE at WIPP has complied 

with the “Compliance reporting” expectations 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 particular the EPA wishes to verify that DOE 

complies with the Subpart A standard is demonstrated by showing that the annual radiation dose 

to any member of the public in the general environment falls below the regulatory limits. 

Focal Areas for this Years Inspection: 

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

#During past years a number of potential changes 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 air flow, what have been the conditions of the 

sample filters? Have the filters had salt buildup 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 procedure has been developed by 

the site that is used to predict probe pull/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 laboratory 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 procedures used to calculate off-normal potential 

release during operations, use flow charts, photographs, etc as needed. Provide examples 

of various accidental scenarios with appropriate calculations-source term estimates, etc. 
6

Describe the process from start to finish, the steps taken to respond to off-normal 

situations? 

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

taken at Station A are representative samples? 

Location: This inspection will be held at the WIPP facility located twenty-six miles south east 

of Carlsbad, New Mexico and the surrounding vicinity as needed. 

Duration: 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 measurements are taken and complete documentation 

that shows how compliance calculations are performed with an explanation of all input 

parameters and their derivation and all pertinent related to Subpart A requirements. Provide 

documentation and procedures related to subpart Subpart A compliance activities 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 (Objective Evidence) Result 

Does DOE “...provide reasonable assurance that the 

combined annual dose equivalent to any member of 

the public in the general environment resulting from: 

(1) Discharges of radioactive material and direct 

radiation from such management and storage and (2) 

all operations covered by Part 190; shall not exceed 

25 millirems to the whole body, 75 millirems to the 

thyroid, and 25 millirems to any other critical organ.” 

40 CFR 191.03(a) 

40 CFR 191.03 

Subpart A - 

Environmental 

Standards for 

Management 

and Storage 

DOE has demonstrated that they 

can capture, measure, and calculate 

releases to assure that they are and 

remain below these limits. 

Sat. 

Scope of activities considered in determining 

compliance

1 Does DOE demonstrate that all activities at the 

WIPP up until the point of disposal are 

considered in determining compliance? 

EPA 402-R97-001 

Section 2.3, 

Page 4 

The Annual Site Environmental Report for 2008 

(DOE/WIPP 09-2225:COB-A2010-C) Executive 

Summary documents the results of DOE’s efforts to 

consider all activities that 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 Implementation 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 Emergency 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 the 

member 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 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 (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 model will be used to 

calculate radiation 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 report demonstrates 

that DOE is using appropriate parameters 

in dose calculations. 

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 9x105

cm3

/hr. 

Assume ingestion rate of meat to be 85 

kg/yr. 

Assume ingestion rate of leafy vegetables 

to be 18 kg/yr. 

Assume ingestion of milk to be 112 

liter/yr. 

Assume ingestion rate of produce to be 176 

kg/yr 

EPA 402-R-97-001 

Section 2.7.3, Page 

10 

Section 3.2 of the Implementation 

Plan for Subpart A (DOE/WIPP 

00-3121:COB-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 monitoring, the effluent air 

stream may be continuously sampled such that 

analysis of filters or other collectors will 

provide an accurate estimate of emissions from 

a known flow rate during a fixed sampling 

time. 

EPA 402-R97-001 

Section 3.1, 

Page 11, (2(ii)) 

DOE uses periodic monitoring at WIPP to 

show compliance with 40 CFR 191 Subpart 

A. The Implementation Plan for Subpart A 

(DOE/WIPP 00-3121:COB-A2010-A) 

Section 3.3.3 states that 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-A2010-F) Section 

1.0 documents that DOE used these 

principles. 

Sat 

25 If DOE is using the “Shrouded Probe”, 

does DOE demonstrate that this 

alternative method is being used 

according to the guidance provide in “An 

Explanation of Particle Sampling in a 

Moving Gas Stream Within a Duct Using 

an Unshrouded and Shrouded Probe”? 

EPA 402-R97-001 

Section 3.1, 

Page 12, 

(2(iii)(a)) 

An Assessment of the WIPP Shrouded 

Probe Against EPA Approval Criteria for 

Use of Single Point Sampling with the 

Shrouded Probe HA:98:0100 (Included in 

August 2000 Inspection Report, A-98-49, 

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

DOE’s evaluation of the Shrouded Probe 

and its compliance with the EPA criteria. 

Single Point Representative Sampling with 

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

probe was qualified for use at WIPP. 

Sat. 
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 underestimate the emissions; 

(iii) DOE shows the alternative procedure is 

fully documented; and 

(iv) DOE has received prior approval from 

EPA. 

EPA 402-R-97-001 

Section 3.1, Page 

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

See question #19, DOE uses 

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

NA. 

28 Does DOE demonstrate that radionuclide 

emission measurements are in 

conformance with the methods in Section 

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

points which have a potential to discharge 

radionuclides into the air in quantities 

which could cause a combined annual dose 

equivalent in excess of 1% of the dose 

limit in Subpart A? 

EPA 402-R-97-001 

Section 3.1, Page 

12 and page 13, 

(4(i)) 

Section 3.3.3 of DOE/WIPP 00-

3121 documents DOE’s 

compliance with this requirement. 

Sat. 

29 Does DOE demonstrate that all 

radionuclides which could contribute 

greater than 10% of the combined annual 

dose equivalent for a release point are 

being measured? 

EPA 402-R-97-001 

Section 3.1, Page 

13, (4(i)) 

Section 3.3 of DOE/WIPP 00-3121 

documents DOE’s compliance with 

this requirement. Section 2.0 of 

the Periodic Confirmatory 

Measurement Protocol 

(DOE/WIPP 97-2238:COBA2010-B) discusses 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 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: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 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 (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 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-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 Reviewed
Documents Reviewed and Copies Received 

During Inspection

191.03 Subpart A Inspection July 2010 DOE Documents

ID# Document Title Subject Matter Source

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 Received 

During Inspection

191.03 Subpart A Inspection July 2010 DOE Documents

ID# Document Title Subject Matter Source

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 Received 

During Inspection

191.03 Subpart A Inspection July 2010 DOE Documents

ID# Document Title Subject Matter Source

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 Received 

During Inspection

191.03 Subpart A Inspection July 2010 DOE Documents

ID# Document Title Subject Matter Source

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 Received 

During Inspection

191.03 Subpart A Inspection July 2010 DOE Documents

ID# Document Title Subject Matter Source

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 Received 

During Inspection

191.03 Subpart A Inspection July 2010 DOE Documents

ID# Document Title Subject Matter Source

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/WIPPCOB-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 Received 

During Inspection

191.03 Subpart A Inspection July 2010 DOE Documents

ID# Document Title Subject Matter Source

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 Received 

During Inspection

191.03 Subpart A Inspection July 2010 DOE Documents

ID# Document Title Subject Matter Source

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/WIPPCOB-M2010-S18 Culebra Freashwater Head Modeling and Flow Direction DOE/WIPPCOB-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/WIPPCOB-M2010-S27 E-140 Fracture Mapping Photos DOE/WIPPCOB-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