Ms. Cynthia White 

AA:14:01181 

UFC:5480.00 

August 21, 2014 

Director, Center for Environmental Radioanalytical Laboratory Science (CERLS) 

USEPA/NAREL 

540 S. Morris A venue 

Montgomery, AL 36115 

Subject: WASTE ISOLATION PILOT PLANT LABORATORIES RESPONSE TO 

ENVIRONMENTAL PROTECTION AGENCY REPORT REGARDING VERIFICATION 

AND VALIDATION OFWIPP DATA PACKAGES 

The Environmental Protection Agency (EPA) recently performed verification and validation of a 

series of data packages compiled by the Waste Isolation Pilot Plant Laboratories (WIPP Labs) 

during the response to a radiological incident at the WIPP Site. As stated by the EPA, the 

calculation errors should have minimal impact on the usability of the data. It is expected that 

WIPP Labs provide the most defensible data possible; therefore, all corrections and revisions to 

calculations will be made per EPA suggestion, as needed. Also, all necessary corrections to the 

data packages will be made by WIPP Labs and provided to the clients (e.g. Environmental 

Monitoring Department) at WIPP, which can submit the copies to EPA. 

WIPP Labs prepares its data packages according to approved procedures and the clients' 

statement of work (SOW). Our calculation programs are fully validated through the NWP 

controlled software program. The procedures and software are audited annually by the 

Department of Energy and EPA, (i.e. Region 6) as well as WIPP Quality Assurance Department. 

Once the data is delivered to the WIPP Labs' clients, they perform additional validation and use 

their interpretation of the data to prepare the reports to regulatory agencies. 

The data packages that were provided to the EPA for review had not been validated yet by the 

clients. Many of the observations above would have been noted and corrected during their 

validation (i.e. typos, missing pages, collection times, etc). The volume of samples collected 

after the underground event and the limited number of trained validators slowed down this 

process. 

WIPP Laboratories is in the process of customizing a Laboratory Information Management 

System. This will reduce the number of typographical errors in reports as well as standardizing 

the report format for each of our clients. 

P.O. Box 2078 • Carlsbad, New Mexico USA 88221-2078 

Phone: (575) 234-7200 • Fax: (575) 234-7083 
Ms. C. White -2- AA:14:01181 

We would like to thank EPA for taking the time to review the data in such detail. We appreciate 

their recommendations and will use them as an opportunity to improve our program. We would 

also like to thank the Quality Assurance Department of Los Alamos National Laboratory for 

reviewing our response and providing suggestions. 

WIPP Labs would like to take this opportunity to comment on EPA's observations. Please see 

the attached document, which is a point-by-point explanation of the observations noted by the 

EPA, and the corrective actions to be taken. For ease of understanding, the explanations are 

added to the EPA document following each point. 

If you have any questions, please contact me at (575) 234-5516. 

Sincerely, 

Mansour 

Manager 

Akbarzadeh 

Science 

~ 

and Development/WIPP Laboratories 

1400 University Drive 

Carlsbad, N.M. 88220 

Tel. (575) 234~516 

Fax. (576) 887-3061 

E-mail: mansour.akbarzadeh@wipp.ws 

Attachment 

MA:dg 

cc: M. Clark, EPA ED 

J. Edwards, EPA ED 

M. Flynn, EPA ED 

J. Griggs, EPA ED 

D. Schultheisz, EPA ED 

T. Peake, EPA ED 

L. Veal, EPA ED 

J. Wieder, EPA ED 

*ED denotes electronic distribution 

P.O. Box 2078 • Carlsbad, New Mexico USA 88221-2078 

Phone: (575) 234-7200 • Fax: (575) 234-7083