            2014 Compliance Recertification Application (2014 CRA) 
         Compliance Application Review Document (CARD Section 194.21)
                                  Inspections
                                       
21.0  Background

	Section 194.21, Inspections, provides the U.S. Environmental Protection Agency (EPA or Agency) with the right to inspect all activities at the Waste Isolation Pilot Plant (WIPP) and all activities located off-site which provide information included in any compliance application.  The Agency can conduct periodic inspections to verify the adequacy of information included in the compliance applications.  The Agency can conduct its own laboratory tests, in parallel with those conducted by DOE to confirm the adequacy of the techniques employed at those facilities.  The Agency may also inspect any relevant records kept by DOE.

      This provision of EPA's Compliance Criteria was not applied prior to the 1998 Certification Decision.  EPA used the authority given by Section 194.21 to inspect WIPP site activities, waste generator sites, the monitoring program, and magnesium oxide (MgO) backfill and waste emplacement requirements after 1998.  These inspections were performed to assure DOE met the requirements.

21.1  Requirements

	(a) "The Administrator or the Administrator's authorized representative(s) shall, at any time:
      
		(1) Be afforded unfettered and unannounced access to inspect any area of 			the WIPP, and any locations performing activities that provide information 		relevant to compliance application(s), to which the Department has rights 			of access. Such access shall be equivalent to access afforded Department 			employees upon presentation of credentials and other required documents.
      
		(2) Be allowed to obtain samples, including split samples, and to monitor 			and measure aspects of the disposal system and the waste proposed for 			disposal in the disposal system."
      
	(b) "Records (including data and other information in any form) kept by the Department pertaining to the WIPP shall be made available to the Administrator or the Administrator's authorized representative upon request. If requested records are not immediately available, they shall be delivered within 30 calendar days of the request."
      
	(c) "The Department shall, upon request by the Administrator or the Administrator's authorized representative, provide permanent, private office space that is accessible to the disposal system. The office space shall be for the exclusive use of the Administrator or the Administrator's authorized representative(s)."
      
	(d) "The Administrator or the Administrator's authorized representative(s) shall comply with applicable access control measures for security, radiological protection, and personal safety when conducting activities pursuant to this section."

21.2  1998 Certification Decision

	No inspections under this authority were conducted prior to the 1998 Certification Decision; therefore, no evaluation related to inspections was completed during the certification review

21.3  Changes in the 2004 Compliance Recertification Application (2004 CRA)

	The 2004 Compliance Recertification Application (2004 CRA) did not specifically address EPA's inspection activities under Section 194.21.

21.3.1  Evaluation of Compliance for 2004 Recertification

      The inspections section of the compliance criteria, 40 CFR 194.21, lists specific requirements related to EPA's ability to perform inspections involving WIPP.  These requirements include; unfettered and unannounced access equivalent to DOE employees, availability of records for review, and private office access if needed to perform inspections.  

	EPA evaluated DOE implementation of these requirements	at each of the twenty-one inspections performed since the 1998 Certification Decision.  DOE provided unfettered access to facilities, access to and list of records as requested by EPA, and actively supported our inspection activities.

21.3.1.1  Monitoring Inspections

	EPA inspects the implementation of the monitoring requirements for geomechanical, hydrological, waste activity, drilling related, and subsidence parameters.   40 CFR Part 194.42(a), requires DOE to "conduct an analysis of the effects of disposal system parameters on the containment of waste in the disposal system."  The results of these analyses were included in the 1998 Compliance Certification Application (CCA) and were used to develop pre-closure and post-closure monitoring requirements.

	Volume 1, Section 7.0, of the CCA documented DOE's analysis of monitoring parameters.  Table 7-7 of the CCA lists the ten parameters that DOE determined may affect the disposal system.  These parameters are grouped into major categories and listed in Table CARD 21-1.  DOE revisited the 40 CFR 194.42 requirements and reevaluated monitor parameters as part of the 2004 CRA, this is documented in 2004 CRA Volume 1 Chapter 7.2 and the Agency's review is discussed in 2004 CRA CARD 42.

Table CARD 21-1  Monitored Parameters
Geomechanical Parameters-			Waste Activity Parameter-
            -Creep closure, 					-Waste Activity
	-Extent of deformation, 
	-Initiation of brittle deformation, and 	Subsidence Parameter-
	-Displacement of deformation features.		-Subsidence measurements

Hydrological Parameters-				Drilling Related Parameters-
            -Culebra groundwater composition and 		-Drilling rate and 
	-Change in Culebra groundwater flow 		-The probability of encountering a 
	  direction.						  Castile brine reservoir.

      Monitoring inspection activities included an examination of monitoring and sampling equipment both on and off site, and in the underground.  EPA also reviewed numerous sampling procedures and measurement techniques and verified implementation of an effective quality assurance program for monitor activities. 

	Results of EPA's monitoring inspections are described in Table CARD 21-2 below.  EPA found few issues during the seven monitoring inspections.   Please see each inspection report for details of each inspection, and see the reference section below for Docket reference information.  EPA found the overall parameter monitoring program adequate to capture potential changes in the ten monitoring parameters and to verify predictions of the compliance performance assessment.

	Monitoring inspection reports are available from the EPA Air Docket A-98-49, Item II-B3.

   Table CARD 21-2 Summary of the 2004 Parameter Monitor Inspections Results

Date of Parameter     Monitor Inspection
Inspection Results: [See Inspection Reports For Details]
March 23, 1999
During this inspection the Agency found that DOE adequately implemented programs to monitoring these ten parameters during pre-closure operations.  EPA did not have any findings or concerns during this inspection.
June 20, 2000
During this inspection the inspectors found that DOE continued to adequately implemented programs to monitoring these ten parameters during pre-closure operations.  EPA did not have any findings or concerns during this inspection.
June 19, 2001
Inspectors concluded that DOE had adequately maintained programs to monitor the necessary ten parameters during pre-closure operations, except for the subsidence monitoring program.  Inspectors found that the subsidence monitoring program at WIPP was not able to show that it had an implemented effective quality assurance program.  EPA found that the Subsidence Program did not have developed adequate written procedures.
June 24, 2002
Inspectors concluded that DOE had adequately maintained programs to monitor the necessary ten parameters during pre-closure operations.  EPA evaluated the new subsidence procedure and found it to be adequate and a significant improvement. EPA did not have any findings or concerns during this inspection.
June 17, 2003
Inspectors concluded that DOE had adequately maintained programs to monitor the necessary ten parameters during pre-closure operations.  EPA had no findings or concerns, but did have one observation.  For some of the parameters that are required to be monitored, such as some geomechanical and waste activity parameters, EPA observed that it was not clear that they were reported properly.  During the inspection DOE committed to make sure that all monitored parameters were clearly reported annually.
June 28, 2004
Based on program documents, interviews, and field demonstrations during the inspection, EPA concluded that the monitoring program covers the ten monitored parameters required in the certification decision; that the monitoring, sample collection, and sample/data analysis procedures reviewed were complete and appropriate; that staff were adequately trained and implemented the procedures adequately; and that appropriate quality assurance measures were applied.  EPA did not have any findings or concerns during this inspection.
July 12, 2005
Based on program documents, interviews, and field demonstrations during the inspection, EPA concluded that the monitoring program covered the ten monitored parameters required in the certification decision; that the monitoring, sample collection, and sample/data analysis procedures reviewed were complete and appropriate; that staff were adequately trained and implemented the procedures adequately; and that appropriate quality assurance measures are applied.  EPA did not have any findings or concerns during this inspection.

21.3.1.2  Waste Emplacement Inspections

	EPA inspected the WIPP to verify that waste was being emplaced in the underground facility in the manner described in DOE's CCA (EPA Air Docket A-93-02, Item II-G-01, and associated documents).  These inspections also verified the proper emplacement of the MgO backfill material with the waste packages.  

	EPA found during these inspections that DOE adequately emplaced waste and MgO backfill material and that emplaced waste was traceable using the WIPP Waste Information System (WWIS) database.  Table CARD 21-3 describes a brief summary of each waste emplacement inspection.  Please see each inspection report for details of each inspection, and see the reference section below for Docket reference information.  

   Table CARD 21-3 Summary of the 2004 Waste Emplacement Inspections Results

Date of Waste   Emplacement Inspection
Inspection Results: [See Inspection Reports For Details]
September 8, 1999
EPA found that waste is being emplaced in accordance with commitments made in the CCA.  EPA did not have any findings or concerns during this inspection.
June 20, 2000
EPA found that waste is being emplaced in accordance with commitments made in the CCA.  EPA did not have any findings or concerns during this inspection.
June 19, 2001
EPA found that waste is being emplaced in accordance with commitments made in the CCA.  EPA did not have any findings but one concern during this inspection.  EPA found that DOE did not appear to have a procedure that required proper documentation of off-normal events, in this case waste was shipped without proper documentation.  
June 24, 2002
EPA did not have any findings or concerns during this inspection.
June 17, 2003
EPA had one finding during this inspection.  EPA found that DOE may not be accounting for random waste emplacement assumptions properly.  
June 28, 2004
EPA did not have any findings but did have one concern. EPA found that magnesium oxide (MgO) was not being properly tracked in the WIPP Waste Information System (WWIS). 
May 17, 2005
EPA did not have any findings but did have one concern during this inspection.  EPA found that DOE needed to develop a formal procedure that guides the MgO emplacement decision making process, rather than use training materials, and that the WWIS needs to be back populated with the quantity of emplaced MgO.

	EPA did not receive any public comments on DOE's continued compliance with the inspections requirements of Section 194.21.

21.3.2  2004 Recertification Decision 

	Based on a review and evaluation of the 2004 CRA and supplemental information provided by DOE (FDMS Docket ID No. EPA-HQ-OAR-2004-0025, Air Docket A-98-49), EPA determined that DOE continued to comply with the requirements for Section 194.21.

21.4  Changes in the 2009 Compliance Recertification Application (2009 CRA)

21.4.1  Evaluation of Compliance for 2009 Recertification

      The inspections section of the compliance criteria, 40 CFR 194.21, lists specific requirements related to EPA's ability to perform inspections involving WIPP as noted in Section 21.3.1 of this CARD.  EPA evaluated DOE implementation of these requirements at each of the eight inspections performed since the 2004 CRA decision was published in 2006.  DOE continued to provide unfettered access to facilities and records as requested by EPA, and actively supported our inspection activities.

21.4.1.1  Monitoring Inspections

	Results of EPA's monitoring inspections since the 2004 CRA are described in Table CARD 21-4 below.  EPA found few issues during the three monitoring inspections.   Please see each inspection report for details of each inspection, see the reference section A-98-49, Items in II-B3.  EPA continued to find the overall parameter monitoring program adequate to capture potential changes in the ten monitoring parameters and to verify predictions of the compliance performance assessment.
        Table CARD 21-4 Summary of Parameter Monitor Inspection Results
                      Since the 2004 CRA Decision in 2006

Date of Parameter     Monitor Inspection
Inspection Results: [See Inspection Reports For Details]
June 20-22, 2006
Based on program documents, interviews, and field demonstrations during the inspection, EPA concluded that the monitoring program covers the ten monitored parameters required by EPA's 1998 Certification Decision.  This inspection determined that the monitoring, sample collection, and sample/data analysis procedures were complete and appropriate; that staff were adequately trained and implemented the procedures adequately; and that appropriate quality assurance measures were applied.  For these reasons, EPA finds that DOE had maintained adequate parameter monitoring during the past year and had the procedures and requirements in place to sustain their program into the next year.  EPA had no findings or concerns.  Docket No: A-98-49, Item: II-B3-97
July 10-12, 2007
Based on program documents, interviews, and field demonstrations during the inspection, EPA concluded that the monitoring program covers the ten monitored parameters required by EPA's 1998 Certification Decision.  This inspection determined that the monitoring, sample collection, and sample/data analysis procedures were complete and appropriate; that staff were adequately trained and implemented the procedures adequately; and that appropriate quality assurance measures are applied.  For these reasons, EPA continued to find that DOE had maintained adequate parameter monitoring during the past year and has the procedures and requirements in place to sustain their program into the next year.  EPA had no findings or concerns.  Docket No: A-98-49, Item: II-B3-102
July 22-24, 2008
Based on program documents, interviews, and field demonstrations during the inspection, EPA concluded that the monitoring program covers the ten monitored parameters required by EPA's 1998 Certification Decision.  This inspection determined that the monitoring, sample collection, and sample/data analysis procedures were complete and appropriate; that staff were adequately trained and implemented the procedures adequately; and that appropriate quality assurance measures are applied.  EPA continued to find that DOE had maintained adequate parameter monitoring during the past year and had the procedures and requirements in place to sustain their program into the next year.  EPA had no findings or concerns.  Docket No: A-98-49, Item: II-B3-108
21.4.1.2  Waste Emplacement Inspections

	EPA continued to inspect the WIPP to verify that waste is being emplaced in the underground facility in the manner described in DOE's CCA and 2004 CRA.  Table CARD 21-5 describes a brief summary of each waste emplacement inspection.  Please see each inspection report for details of each inspection, see the reference section A-98-49, Items on II-B3.  

        Table CARD 21-5 Summary of Waste Emplacement Inspection Results
                      Since the 2004 CRA Decision in 2006

Date of Waste   Emplacement Inspection
Inspection Results: [See Inspection Reports for Details]
June 20-22, 2006
The inspectors reviewed the emplacement operation and the associated documentation for selected shipments.  It was determined that DOE was adequately emplacing waste in the repository as specified in the CCA dated May 18, 1998.  EPA concluded from this inspection that DOE's emplacement activities were adequate, the cellulose, plastics, rubber (CPR) waste component amounts were appropriately tracked, the safety factor was calculated properly along with the additional MgO needed (since DOE began to track the MgO), and that all MgO was emplaced properly.  DOE calculated that the current safety factor was above the mandated 1.67 for closed rooms since the tracking officially began with Room 1, Panel 2 and Room 7, Panel 3.  EPA did not identify any findings during this inspection. Docket No: A-98-49, Item: II-B3-97
July 10-12, 2007
The inspectors reviewed emplacement operations and associated documentation for selected containers.  EPA concluded that DOE's emplacement activities are adequate, that CPR is appropriately tracked, the safety factor was calculated properly, additional MgO was added as needed, and that all MgO was emplaced properly 

The surface processing of RH and the underground operation of RH container emplacement were explained and found to be according to specified plans documented in CCA.  EPA did not identify any findings or concerns during this inspection. However, EPA recommended that DOE maintain a permanent photographic record of the RH canister number as it is removed from the transportation cask. Docket: A-98-49, Item II-B3-102
July 22-24, 2008
The inspectors reviewed emplacement operations and associated documentation for selected containers.  EPA concluded that DOE's emplacement activities were adequate, that CPR amounts were appropriately tracked, the safety factor is calculated properly, additional MgO was added as needed, and that all MgO is emplaced properly.  DOE noted that the current safety factor was above the mandated 1.67 for closed rooms since the tracking officially began with Room 1, Panel 2 and Room 7, Panel 3 at the time of the inspection. 

The surface processing of RH and the underground operation of RH container emplacement were reviewed and found to be adequate according to specified plans documented in the CCA.  EPA did not identify any findings or concerns during this inspection. However, EPA recommended again that DOE maintain a permanent photographic record of the RH canister number as it is removed from the transportation cask.  Docket No: A-98-49, Item: II-B3-108




21.4.1.3  Other Inspections

	EPA performed two other inspections since the 2004 CRA, including a review of DOE's Remote-handled (RH) waste emplacement plans, process, and procedures and DOE's document development procedures and processes.  The purpose of the RH inspection was to verify that the WIPP site was prepared to begin receiving RH waste.  The primary purpose of the document development inspection was to review how DOE, SNL and LANL produce, review and verify the documents they provide to EPA.  EPA looked at selected activities, such as document development, project analyses, verification of calculations, and final approval activities.    Table CARD 21-6 describes a brief summary of other inspections done since the 2004 CRA decision was published in 2006. 
              Table CARD 21-6 Summary of Other Inspection Results
                      Since the 2004 CRA Decision in 2006

Date of Other Inspections
Inspection Results: [See Inspection Reports for Details]
January 9-11, 2007          RH Startup Inspection
EPA observed the processing of a test RH canister from a 72B transportation cask beginning with the canister's removed from the transportation cask. Although there was a problem with the weight sensor on the grapple in the waste handling building, the waste handling staff appeared to appropriately diagnose the problem and had a process (a work package) to deal with the problem. The underground disposal operations that the EPA inspectors observed proceeded according to procedures with no malfunctions.

There were no findings or concerns identified in this inspection.  DOCKET No: A-98-49, Item: II-B3-101
November 27-28, 2007  Document Review-Technical Inspection
As a result of this inspection EPA identified that, while DOE, SNL, and LANL have procedures in place that direct the production and review of documents, there is room for improvement, such as modifications to procedures.  In addition, EPA identified process improvements that can clarify what communications come from EPA to DOE.  Docket No: A-98-49, Item: II-B3-103

	EPA did not receive any public comments on DOE's continued compliance with the inspections requirements of Section 194.21.

21.4.2  2009 Recertification Decision 

	Based on a review and evaluation of the 2009 CRA and supplemental information provided by DOE (FDMS Docket ID No. EPA-HQ-OAR-2009-0330, Air Docket A-98-49), EPA determined that DOE continued to comply with the requirements for Section 194.21.

21.5  Changes in the 2014 Compliance Recertification Application (2014 CRA)

21.5.1  Evaluation of Compliance for 2014 Recertification

      EPA evaluated DOE implementation of the requirements of section 40 CFR 194.21 during seven inspections performed since the 2009 CRA.  DOE continued to provide unfettered access to facilities and records as requested by EPA, and actively supported the Agency's inspection activities.

21.5.1.1  Monitoring Inspections

	Results of EPA's monitoring inspections since the 2009 CRA are described in Table CARD 21-7 below.   Please see each inspection report for details of each inspection. Note that in February of 2014, two separate incidents  -  a salt haul truck fire and a radiological release - took place, which halted facility operations and restricted access to many areas of the underground for months.  In April 2014, EPA conducted an inspection in response to the radiological release, but did not address the monitoring of parameters. EPA resumed annual inspections of parameter monitoring in 2015 and 2016. EPA continued to find the overall parameter monitoring program adequate to capture potential changes in the ten monitoring parameters and to verify predictions of the compliance performance assessment.
      Table CARD 21-4 Summary of Parameter Monitoring Inspection Results
                              Since the 2009 CRA 

Date of Parameter    Monitoring Inspection
Inspection Results: [See Inspection Reports For Details]
July 14-16, 2009
Based on program documents, interviews, and field demonstrations during the inspection, EPA concluded that the monitoring program covers the ten monitored parameters required by EPA's 1998 Certification Decision.  This inspection determined that the monitoring, sample collection, and sample/data analysis procedures were complete and appropriate; that staff were adequately trained and implemented the procedures adequately; and that appropriate quality assurance measures were applied.  EPA had no findings or concerns.  Docket No: A-98-49, Item: II-B3-111
June29-July 1, 2010
The EPA found that DOE continues to effectively implement the monitoring programs for the ten monitoring parameters required by EPA's 1998 Certification Decision. The inspectors also confirmed that the results of DOE monitoring programs are reported annually. Based on program documents, interviews, and field demonstrations during the inspection, EPA concluded that the monitoring program covers This inspection determined that monitoring sample collection, and sample/data analysis procedures were complete and appropriate; that staff were adequately trained and implemented the procedures adequately; and that appropriate quality assurance measures are applied. EPA did not have any findings or concerns. Docket No: A-98-49, Item: II-B3-112
May 10-12, 2011


Based on program documents, interviews, and field demonstrations during the inspection, EPA concluded that the monitoring program covers the ten monitored parameters required by EPA's 1998 Certification Decision.  This inspection determined that the monitoring, sample collection, and sample/data analysis procedures were complete and appropriate; that staff were adequately trained and implemented procedures adequately; and that appropriate quality assurance measures are applied.    EPA had no findings or concerns.  Docket No: A-98-49, Item: II-B3-116
July 17-19, 2012
The inspection examined the implementation of monitoring for geomechanical, hydrological, waste activity, drilling-related, and subsidence parameters. The EPA inspectors toured locations
where measurements are taken, reviewed parameter databases, and reviewed documents and procedures directing these monitoring activities. EPA found that DOE continues to effectively implement the monitoring programs at WIPP for all areas reviewed. The inspectors also confirmed that the results of DOE monitoring programs are reported annually. EPA did not have any findings or concerns. Docket No: A-98-49, Item: II-B3-125
 October 22- 24, 2013
The inspection examined the implementation of monitoring for geomechanical, hydrological, waste activity, drilling-related, and subsidence parameters. The EPA inspectors toured locations where measurements are taken, reviewed parameter databases, and reviewed documents and procedures directing these monitoring activities. The Agency found that DOE continues to effectively implement the monitoring programs at WIPP for all areas reviewed. The inspectors also confirmed that the results of DOE monitoring programs are reported annually. EPA did not identify any findings or concerns during this inspection. Docket No: A-98-49, Item: II-B3-127 
                               April 7 -9 , 2015

During the April 2015 inspection, the facility was undergoing active recovery and not emplacing waste. Therefore, this inspection focused on changes in the monitoring program as a result of the 2014 incidents, gaps in monitoring data and their significance, and changes to documentation or procedures. The EPA found that the site had minimized the effect of the incident, and had adapted its procedures and continued to effectively implement all parameter monitoring programs at WIPP. The inspectors confirmed that the results of DOE monitoring programs continued to be reported annually had no findings or concerns. E-DOCKET NO:  EPA-HQ-OAR-2001-0012-0457

 November 7-9, 2016
Based on program documents, interviews, and field demonstrations during the inspection, the EPA concluded that the monitoring program covers the ten monitoring parameters required by the EPA's 1998 Certification Decision. This inspection determined that monitoring sample collection, and sample/data analysis procedures were complete and appropriate; that staff were adequately trained and implemented the procedures adequately; and that appropriate quality assurance measures are applied. E-DOCKET: EPA-HQ-OAR-2001-0012-0469


21.4.1.2  Waste Emplacement Inspections

	EPA continued to inspect the WIPP to verify that waste is being emplaced in the underground facility in the manner described in DOE's CCA and 2009 CRA. As with parameter monitoring, the February 2014 fire and release at WIPP precluded a waste emplacement inspection from taking place in 2014, because the incidents restricted access to the underground facility. Partial access was restored in late April 2014, and inspections following the format of the monitoring and waste emplacement inspections resumed in 2015 and 2016. Waste emplacement did not resume until January 3, 2017, however. The 2015 and 2016 inspections focused on the management and tracking of stored waste. Table CARD 21-5 describes a brief summary of each waste emplacement inspection.  Please see each inspection report for details of each inspection. Reports are located in Docket A-98-49, Cateogry II-B3 and e-docket EPA-HQ-OAR-2001-0012 (via www.regulations.gov). The most recent WIPP site inspection reports can be found at item EPA-HQ-OAR-2001-0012-0469.  

        Table CARD 21-5 Summary of Waste Emplacement Inspection Results
                      Since the 2004 CRA Decision in 2006

Date of Waste   Emplacement Inspection
Inspection Results: [See Inspection Reports For Details]
July 14-16, 2009
EPA examined RH and CH waste processing, waste emplacement activities, and record keeping. EPA placed emphasis on the emplacement and tracking of the magnesium oxide (MgO) engineered barrier, due to the fact that DOE implemented its planned change to reduce the MgO safety factor to 1.2 in the interim since EPA's most recent (July 2008) emplacement inspection. EPA concluded that DOE's emplacement activities are adequate, that cellulosic, plastic and rubber (CPR) material is appropriately tracked and recorded, and that DOE's planned change to an MgO safety factor of 1.2 has been implemented properly. Specifically, the CPR/MgO excess factor is calculated correctly and regularly on a room-by-room basis, MgO is emplaced as needed, and that steps have been taken to assure that MgO reactivity is retained. EPA observed that the WIPP Waste Handling User's Manual (WP 05-WH.01) should be updated to reflect recent changes to individual procedures, and did not identify any findings or concerns during this inspection. Docket No: A-98-49, Item: II-B3-111
June 29-July 1, 2010
The inspectors reviewed emplacement operations and associated documentation for selected containers.  During this year's inspection EPA placed specific emphasis on the tracking of emplaced waste and magnesium oxide (MgO) engineered barrier using the WDS, due to the fact that DOE implemented the new WDS to replace the WIPP
Waste Information System (WWIS) in the interim since EPA's most recent (July 2009) emplacement inspection.
EPA concluded that DOE's emplacement activities are adequate, that CPR is appropriately tracked and recorded, that MgO balances are calculated properly, and that MgO is emplaced properly. EPA observed the use of the proper waste emplacement procedures in the underground, and successful implementation of the WDS waste container bar code reader. EPA did not identify any findings or concerns during this inspection. Docket: A-98-49, Item II-B3-112 
July 22-24, 2011
EPA observed the use of the proper waste emplacement procedures in the underground and successful implementation of the WDS bar code reader. The inspectors reviewed emplacement operations, WTS procedures, and records associated with selected containers. EPA concluded that DOE's emplacement activities are adequate, that cellulosic, plastic and rubber material (CPR) is appropriately tracked and recorded, that MgO balances are calculated properly, and that MgO is emplaced properly. EPA identified no findings or concerns. Docket No: A-98-49, Item: II-B3-116
July 17-19, 2012
The inspectors reviewed emplacement operations, procedures, and records associated with selected containers. EPA concluded that DOE's emplacement activities and records are adequate, and that CPR and MgO are appropriately tracked. EPA identified no findings or concerns. DOCKET NO: A-98-49 Item: II-B3-125

 October 22  -  24, 2013
The inspectors reviewed emplacement operations, procedures, and records associated with selected containers. The Agency observed the use of the proper waste emplacement procedures in the underground. EPA did not identify any findings or concerns during this inspection. The surface processing of CH and RH waste as well as underground operations were reviewed and found to be adequate, according to specified plans documented in the CCA. EPA concluded that DOE's emplacement activities are adequate, that cellulosic, plastic and rubber material (CPR) is appropriately tracked and recorded, that MgO balances are calculated properly, and that MgO is emplaced properly. EPA identified no findings or concerns. DOCKET NO: A-98-49 Item: II-B3-127


April 7-9 2015
 WIPP experienced two events in February, 2014, that suspended waste emplacement and required recovery operations in the underground. During the April 2015 inspection, the facility was undergoing active recovery and not emplacing waste. The emplacement inspection was used to document recovery progress and confirm information DOE submitted to EPA regarding recovery.  EPA confirmed Waste Data System (WDS) records for waste currently stored in the Waste Handling Building, toured uncontaminated areas of the underground, and observed recovery activities. EPA did not identify any findings or concerns during the Emplacement portion of the inspection. E-DOCKET NO:  EPA-HQ-OAR-2001-0012-0458

 November 7-9, 2016
During the November 2016 inspection, the facility had not emplaced waste since February of 2014, and was undergoing final readiness reviews in anticipation of resuming waste emplacement. EPA inspectors confirmed information the DOE has submitted to the Agency regarding recovery and observed the state of the repository and its operations shortly before the resumption of waste emplacement. The EPA viewed Waste Data System (WDS) records for waste currently stored in the Waste Handling Building, toured the underground and observed the results of recovery activities taken to return the facility to operation. EPA inspectors also reviewed documentation of training and exercise activities undertaken by WIPP management and staff to adapt to operational changes at the facility and prepare for restart. The procedures for processing CH waste upon facility restart were reviewed. The Agency identified no findings or concerns.  E-DOCKET: EPA-HQ-OAR-2001-0012-0469




21.4.1.3  Other Inspections

	EPA performed no other other inspections for the purposes of verifying compliance with 40 CFR part 194 since the 2009 CRA. EPA did not receive any public comments on DOE's continued compliance with the inspections requirements of Section 194.21.

21.4.2  2014 Recertification Decision 

	Based on a review and evaluation of the 2009 CRA and supplemental information provided by DOE (FDMS Docket ID No. EPA-HQ-OAR-2014-0609, Air Docket A-98-49), EPA determines that DOE continues to comply with the requirements for Section 194.21.

