Ms. Cynthia White AA:14:01181 UFC:5480.00

August21, 2014

Director, Centerfor Environmental Radioanalytical Laboratory Science (CERLS) USEPA/NAREL 540 S. Morris Avenue 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 ofdata packages compiled by the Waste Isolation Pilot Plant Laboratories (WIPP Labs) during the response to a radiological incident at the WIPP Site. As statedbythe EPA, the calculation errors shouldhave minimalimpacton the usabilityofthe 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) atWIPP, which can submit the copies to EPA. WIPP Labs prepares its data packages according to approved procedures and the clients' statementofwork (SOW). Ourcalculation 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 QualityAssurance Department. Once the data is delivered to the WIPP Labs' clients, they perform additional validation and use their interpretation ofthe data to prepare the reports to regulatory agencies. The data packages thatwere provided to the EPA for review had not been validated yet by the clients. Many ofthe observations above would have been noted and corrected during their validation (i.e. typos, missing pages, collection times, etc). The volume of samples collected afterthe underground event and the limited number oftrained validators slowed down this process. WIPP Laboratories is in the process ofcustomizing a Laboratory Information Management System. This will reduce the number oftypographical errors in reports as well as standardizing the report formatforeach ofour clients.

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.O. Box 2078 • Carlsbad, New Mexico USA 88221-2078 Phone: (575) 234-7200 • Fax: (575) 234-7083

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## C. White -2- AA:14:01181

Wewould like to thank EPA fortaking the time to review the data in such detail. We appreciate their recommendations and will use them as an opportunity to improve our program. Wewould 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 ofthe observations noted by the EPA, and the corrective actions to be taken. Forease of understanding, the explanations are added to the EPA documentfollowing each point. Ifyou have any questions, please contact me at (575) 234-5516. Sincerely,



# ~ MansourAkbarzadeh ManagerScience 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 

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. Griggs, EPA ED D. Schultheisz, EPA ED 

### T. Peake, EPA ED 

### L. Veal, EPA ED J. Wieder, EPA ED *ED denotes electronic distribution

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. Box 2078 • Carlsbad, New Mexico USA 88221-2078 Phone: (575) 234-7200 • Fax: (575) 234-7083