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					              2.      ENVIRONMENTAL COMPLIANCE SUMMARY

     Operations at the Idaho National                  determination is made whether a no further
Engineering and Environmental Laboratory               action listing is possible or if it is appropriate
(INEEL) are subject to numerous Federal,               to proceed with an interim cleanup action or
and State environmental statutes and                   further investigation using a remedial
regulations. These are listed in Appendix A.           investigation/ feasibility study (RI/FS).
A brief summary of the INEEL's status with             Results from the RI/FS form the basis for
these regulations is presented in the                  assessment of risks and alternative cleanup
following sections.                                    actions. After reviewing public comments,
                                                       DOE-ID, EPA, and the State reach a final
       2.1 COMPLIANCE STATUS                           decision, which is documented in a Record
                                                       of Decision (ROD). Cleanup activities then
Comprehensive Environmental                            can be designed, implemented, and
Response, Compensation, and Liability                  completed.
Act
                                                           The INEEL is divided into 10 Waste
  The      Comprehensive        Environmental          Area Groups (WAGs) containing 26 areas
Response, Compensation, and Liability Act              for conducting environmental investigations
(CERCLA) provides broad Federal authority              as a result of the FFA/CO. By the end of
to respond directly to releases or potential           2000, 21 investigations were complete with
releases of hazardous substances that may              legally binding RODs. The remaining
endanger public health or the environment.             investigations to be completed include:
Through the National Contingency Plan,
CERCLA provides specific procedures to                 •   A combined investigation of the
assess and remediate areas of actual or                    Experimental Breeder Reactor No. 1
potential releases. The ultimate goal of                   (EBR-I)/Boiling   Water     Reactor
CERCLA actions is to reduce or eliminate                   Experiment area and contaminated
the potential risk to human health and the                 surface     areas  outside   facility
environment from these potential or actual                 boundaries;
releases.    Nuclear research and other                •   Buried waste at the Radioactive Waste
operations left behind contaminants that                   Management Complex (RWMC);
pose a potential risk to human health and
                                                       •   Soil and groundwater contamination at
the environment. The INEEL was placed on
                                                           the Idaho Nuclear Technology and
the National Priorities List under CERCLA
                                                           Engineering Center (INTEC) Tank Farm;
on November 29, 1989. Environmental
                                                           and
restoration activities at the INEEL are being
conducted in accordance with the Federal               •   Snake River Plain Aquifer contamination
Facility Agreement and Consent Order                       from the INEEL.
(FFA/CO) signed in December 1991 by the
                                                           All 15 FFA/CO enforceable milestones
U.S.     Department        of    Energy-Idaho
                                                       scheduled for 2000 were completed during
Operations Office (DOE-ID), the state of
                                                       the year. Cleanup was completed at one
Idaho, and the U.S. Environmental
                                                       area at the INEEL in 2000, bringing the total
Protection Agency (EPA) Region 10.
                                                       number of cleaned up areas to 12. Cleanup
     Field investigations are used to evaluate         actions are in progress at nine other areas.
many potential release sites when existing
                                                       Resource Conservation and
data are expected to indicate that a site
                                                       Recovery Act
needs no further action or where limited
field data collection is necessary. After                 The Resource Conservation and
each investigation is completed, a                     Recovery Act   (RCRA)  established


                                                 2-1
2000 Annual Site Environmental Report


regulatory    standards   for   generation,          Reports
transportation, storage, treatment, and                  As required by the state of Idaho, INEEL
disposal of hazardous waste. The Idaho               submitted the Idaho Hazardous Waste
Department of Environmental Quality (DEQ)            Generator Annual Report for 2000. The
is authorized by EPA to regulate hazardous           report contains information on waste
waste and the hazardous component of                 generation, treatment, recycling, and
mixed waste at the INEEL. Mixed waste                disposal activities at INEEL facilities.
contains both radioactive and hazardous
materials. The Atomic Energy Act, as                     DOE-ID submitted the INEEL 2000
administered through DOE orders, regulates           Affirmative Procurement Report to EPA, as
radioactive wastes and the radioactive part          required by Section 6002 of RCRA and
of mixed wastes.                                     Executive Order 13101.       This report
                                                     provides information on the INEEL's
Notice of Violation                                  procurement of products with recycled
    On May 26, 1999, DOE received a                  content.
Notice of Violation from the Idaho DEQ.
                                                         The INEEL RCRA permit for the
The     alleged     violations  stem    from
                                                     Hazardous Waste Storage Facility at CFA
inspections on April 15-17, June 8-12, June
                                                     and some areas at ANL-W requires
29, July 14-16, July 31, August 12, and
                                                     submittal of an annual certification to DEQ
August 18-24, 1998.          DEQ alleged 86
                                                     that the INEEL has a waste minimization
violations with a fine of $839,550. In 2000,
                                                     program in place to reduce the volume and
DOE-ID and DEQ signed a consent order to
                                                     toxicity of hazardous waste.             The
resolve the alleged violations with a final
                                                     certification was submitted by July 1, 2000.
fine amount of $445,600, of which $170,000
will be used for two Supplemental                        A 45-day Notification for 2000
Environmental Projects ($20,000 to the               Treatability Studies was submitted to DEQ
Shoshone-Bannock Tribes Land Use                     in October 1999. This report was submitted
Department and $150,000 to the Sagebrush             in addition to the notification normally
Steppe Reserve).                                     provided in the DOE Annual Report on
                                                     Treatability Studies submitted to DEQ in
Closure Plans
                                                     March 1999.        Treatability Studies, as
     The state of Idaho approved the                 defined by the regulation [Reference 2-1],
following closure plans in November 2000:            are those in which a hazardous waste is
•   The Heat Transfer Reactor Experiment             subjected to a treatment process to
    No. 3 at EBR-I;                                  determine:
•   Process Experimental Pilot Plant                 •   Whether the waste is amenable to the
    Incinerator and Waste Stabilization at               treatment process;
    TAN; and                                         •   What pretreatment, if any, is required;
•   The Hazardous Chemical Waste                     •   The optimal process conditions needed
    Handling and Neutralization Facility at              to achieve the desired treatment;
    INTEC.
                                                     •   The efficiency of a treatment process for
   Two       additional     facilities were              a specific waste or wastes; and
administratively closed in 2000. They were
the Waste Characterization Facility at the           •   The characteristics and volumes of
RWMC and the Waste Experimental                          residuals from a particular treatment
Reduction Facility Waste Storage/Feed                    process.
Tanks at the Waste Experimental Reduction                The notifications briefly describe the
Facility/Power Burst Facility area.                  types of studies performed on both
                                                     hazardous waste and mixed waste and the



                                               2-2
                                                        Chapter 2: Environmental Compliance Summary


quantities of waste used in the studies. A                  either is below emission thresholds or
Treatability Study is not a means to                        listed as an exempted source category
commercially treat or dispose of hazardous                  in state of Idaho regulations;
waste.
                                                        •   Submittal of an application for a Permit
Federal Facility Compliance Act                             to Construct—if emissions are deemed
                                                            major under Prevention of Significant
    The Federal Facility Compliance Act
                                                            Deterioration   regulations    then    a
requires the preparation of site treatment
                                                            Prevention of Significant Deterioration
plans for the treatment of mixed wastes
                                                            analysis,    as   described     in   the
stored or generated at DOE facilities. Mixed
                                                            regulations, must be completed;
waste contains both hazardous and
radioactive components. The INEEL Site                  •   Request for a Permit to Construct; or
Treatment Plan (STP) was published on
                                                        •   Request for a Permit to Construct for
October 31, 1995. DOE and DEQ devel-
                                                            sources of significant emissions through
oped a Consent Order that provides the
                                                            a Prevention of Significant Deterioration
legal framework for implementing the STP.
                                                            analysis.
By November 1, 1995, both DOE and DEQ
had signed the Consent Order, thereby                       Permitting actions for sources of air
implementing the STP.           For more                pollutants at the INEEL are listed in
information see Section 2.4.                            Section 2.9.
    In November 2000, the annual STP                    Title V Operating Permit
report was submitted to the State for review                 Title V of the 1990 amendments to the
and final approval, and the State approved              Clean Air Act required the EPA to develop a
the report in January 2001. In 2000, the                federally enforceable operating permit
INEEL treated 59.2 m3 (2,090.6 ft3) of mixed            program for air pollution sources to be
waste from offsite sources and 1,214 m3                 administered by state and/or local air
(42,872 ft3) from onsite sources.                       pollution agencies. The EPA promulgated
Clean Air Act                                           regulations in July 1992 that defined the
                                                        requirements for state programs. Idaho has
    The Clean Air Act sets standards for                promulgated regulations and EPA has given
ambient air quality and for emission of                 interim approval of the Idaho Title V
hazardous air pollutants. The EPA is the                Operating Permit program.
federal regulatory agency of authority, but
states may administer and enforce                          The revised INEEL Title V Air Operating
provisions of the Act by obtaining EPA                  Permit Application was submitted to the
approval of a state implementation plan.                Idaho Division of Environmental Quality
Idaho has been delegated such authority.                (DEQ) in March 2001.

     The Idaho air quality program is                   National Emission Standards for Hazardous
primarily    administered      through      the         Air Pollutants
permitting process. Potential sources of air                 DOE-ID submitted the 2000 INEEL
pollutants are evaluated against regulatory             National Emission Standards for Hazardous
criteria to determine if the source is                  Air Pollutants-Radionuclides report to EPA,
specifically    exempt      from     permitting         DOE-Headquarters, and state of Idaho
requirements and if the source's emissions              officials in June 2001. This statute requires
are significant or insignificant. If emissions          the use of the CAP-88 computer model to
are determined to be significant, several               calculate     the   hypothetical   maximum
actions may occur:                                      individual effective dose equivalent to a
                                                        member of the public resulting from INEEL
•   Permitting   Determinations     may
                                                        airborne radionuclide emissions. The 2000
    demonstrate that the project/process



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2000 Annual Site Environmental Report


calculations for this code are discussed              measures to prevent pollution of storm
further in Chapter 7, “Dose to the Public.”           water.     The Storm Water Pollution
                                                      Prevention Plan team conducts annual
Clean Water Act
                                                      evaluations to determine compliance with
    The Clean Water Act (CWA), passed in              the plan and the need for revision. The
1972, established goals to control pollutants         Environmental Monitoring Unit of the
discharged to United States surface waters.           Management      and   Operating    (M&O)
Among the main elements of the CWA are                contractor monitors storm water in
effluent limitations, set by the EPA, for             accordance with the permit requirements
specific industry categories and water                and with DOE orders. Results from this
quality standards set by states. The CWA              monitoring in 2000 are provided in
also provided for the National Pollutant              Chapters 3 and 4.
Discharge Elimination System (NPDES)
                                                          The National Oceanic and Atmospheric
permit program, requiring permits for
                                                      Administration (NOAA) Air Resources
discharges from a point source into surface
                                                      Laboratory-Field      Research      Division
waters.
                                                      provides identification and notification of
Clean Water Act Section 404 Permits.                  storm events.        Storm water pollution
    In October 1994, the U.S. Army Corps              prevention training is provided to INEEL
of Engineers granted a 10-year Section 404            personnel in accordance with the permit
permit that authorizes DOE-ID to discharge            requirements.
dredge and fill material associated with the          Storm Water Discharge Permits for
excavation of soil in Spreading Area B. Fill          Construction Activity
removal activities have ceased in this area               INEEL's General Permit for Storm Water
since then.                                           Discharges from Construction Sites was
Spill Prevention, Control, and                        issued in June 1993. The permit has been
Countermeasure Plans                                  renewed twice since issuance, most
     Only the Test Area North (TAN), the              recently in 1998. The INEEL Storm Water
INTEC, and the RWMC require Spill                     Pollution Prevention Plan for Construction
Prevention, Control, and Countermeasure               Activities (DOE/ID-10425) was distributed in
Plans.      These INEEL facilities were               January 1994 [Reference 2-3]. The plan
evaluated in 2000 in accordance with                  provides for measures and controls to
Title 40 Code of Federal Regulations (CFR),           prevent      pollution of   storm     water.
Part 112.                                             Worksheets are completed for construction
                                                      projects and are appended to the plan.
Storm Water Discharge Permits for                     Inspections of construction sites are
Industrial Activity                                   performed in accordance with permit
    Revised requirements for the NPDES                requirements.
general permit for the discharge of storm             Safe Drinking Water Act
water from industrial activities became
effective in 2000. The INEEL met the                      The Safe Drinking Water Act was
requirements to continue operations under             reauthorized on August 6, 1996.            It
this general permit. A modified NPDES                 establishes primary standards for drinking
Storm Water Multi-sector General Permit for           water delivered by systems supplying
industrial activities was also published in           drinking water to 15 or more connections or
2000. The original INEEL Storm Water                  25 individuals for at least 60 days per year.
Pollution Prevention Plan for Industrial              The INEEL drinking water supplies meet
Activities (DOE/ID-10431) was implemented             those criteria and are classified as either
in 1993 [Reference 2-2]. This plan provides           nontransient noncommunity or transient
for baseline and tailored controls and                noncommunity systems.           The INEEL
                                                      operates 12 active public water systems,


                                                2-4
                                                      Chapter 2: Environmental Compliance Summary


two of which serve NRF and ANL-W. All                 Idaho High-Level Waste and Facilities
INEEL facilities performed sampling of                Disposition Environmental Impact
drinking water as required by the State and           Statement
EPA. See Chapter 5 for details on drinking                This Environmental Impact Statement
water monitoring results.                             (EIS) evaluates potential environmental
Toxic Substances Control Act                          impacts of various alternatives for managing
                                                      high-level radioactive waste (HLW) and
    The Toxic Substances Control Act                  related radioactive wastes and facilities at
(TSCA), which is administered by EPA,                 the INTEC.        The state of Idaho is a
requires testing and regulation of chemical           cooperating agency with DOE in preparation
substances that enter the consumer market.            of the EIS. In 2000, DOE received and
TSCA supplements sections of the Clean                considered agency and public comments on
Air Act, the CWA, and the Occupational                the draft EIS.         In response to those
Safety and Health Act. Since the INEEL                comments and updated information, DOE
does not produce chemicals, compliance                incorporated changes into the final EIS.
with TSCA at the INEEL is primarily directed          The final EIS should be available to the
toward management of polychlorinated                  public in the fall of 2002. The ROD for that
biphenyls (PCBs).                                     EIS will be available no sooner than 30 days
Storage of PCB-contaminated Materials                 after the announcement of the Notice of
     Radioactively  contaminated    PCBs              Availability of the final EIS.
continue to be stored at the INEEL.                   National Historic Preservation Act
Negotiations between the Headquarters
                                                          Preservation of historic properties on
offices of DOE and EPA resulted in a
                                                      lands managed by DOE is mandated under
complexwide agreement (May 8, 1996) for
                                                      Section 106 of the National Historic
storage longer than one year. DOE-ID and
                                                      Preservation Act and amendments. The Act
EPA Region 10 are in the process of
                                                      requires that for any federal undertaking will
resolving issues associated with one-year
                                                      have an adverse effect on historic property,
storage of these materials.
                                                      the cognizant federal agency must enter
National Environmental Policy Act                     into an agreement with the State Historic
    The National Environmental Policy Act             Preservation Officer for the purpose of
(NEPA) requires federal agencies to                   mitigating those adverse effects.
consider      and       analyze     potential             A comprehensive draft Historic Context
environmental impacts of proposed actions             of the INEEL was prepared in 1997. This
and explore appropriate alternatives to               Historic Context contains a historic
mitigate those impacts, including a "no               evaluation of all properties built on the
action" alternative. Agencies are required            INEEL under the DOE-ID’S authority and
to inform the public of the proposed actions,         provides the background with which to
impacts, and alternatives and consider                assess their historic significance. It will be
public feedback in selecting an alternative.          used to guide a more comprehensive
DOE implements NEPA according to                      approach to managing the preservation and
procedures in 10 CFR 1021 and assigns                 documentation of buildings scheduled to be
authorities and responsibilities according to         modified or dismantled.
DOE Order 451.1B. Processes specific to
                                                         Draft Tribal Consultation Procedures
DOE-ID are set forth in its NEPA Planning
                                                      were developed in partnership with the
and Compliance Program Manual, ID M
                                                      Shoshone-Bannock      Tribes.       These
451.A-1. The DOE-ID NEPA Compliance
                                                      procedures provide clarity and guidance to
Officer and NEPA Planning Board
                                                      ensure continued good communication
implement the process.
                                                      between the Tribes, DOE, and the M&O
                                                      contractor regarding cultural resource


                                                2-5
2000 Annual Site Environmental Report


management on the INEEL.                  The             The       Environmental  Surveillance,
procedures are also an integral component              Education and Research Program conducts
of the Agreement-in-Principle, signed in               ecological research, field surveys, and
August 1998, between DOE-ID and the                    NEPA evaluations regarding ecological
Tribes. DOE-ID also organized and hosted               resources on the INEEL.        Particular
a first-of-its-kind Cultural Resource training         emphasis is given to threatened and
course.       The course was specifically              endangered species and species of special
organized to allow for participation and               concern identified by the U.S. Fish and
representation from several Tribes in the              Wildlife Service.
northwest, government agencies, and
                                                           Two federally protected species may
contractor personnel.
                                                       occasionally spend time on the INEEL: the
Native American Graves Protection and                  threatened      Bald      eagle     (Haliaeetus
Repatriation Act                                       leucocephalus) and the Gray wolf (Canis
                                                       lupus).     Gray wolves found in the
     The INEEL is located on the aboriginal
                                                       geographical region that includes the INEEL
territory of the Shoshone and Bannock
                                                       are          identified          as          an
people. The Shoshone-Bannock Tribes are
                                                       experimental/nonessential population and
major stakeholders in INEEL activities. They
                                                       treated as a threatened species. Bald
are particularly concerned with how the
                                                       eagles occasionally winter on part of the
remains of their ancestors and culture are
                                                       INEEL       and       there     have      been
treated by DOE-ID and its contractors. The
                                                       unsubstantiated sightings of Gray wolves.
Native American Graves Protection and
                                                       Ute's ladies tresses (Spiranthes diluvialis)
Repatriation Act (NAGPRA) provides for the
                                                       may occur on the INEEL, but they have
protection of Native American remains and
                                                       never been reported. It is, however, unlikely
the repatriation of human remains and
                                                       that suitable habitat (wet meadows) exists
associated burial objects. Repatriation
                                                       on the INEEL long enough each year to
refers to the formal return of human remains
                                                       support this threatened species.
and cultural objects to the Tribes with whom
they are culturally affiliated. No NAGPRA                  Research and monitoring continued on
items were discovered or repatriated in                several species of special biological,
2000.                                                  economic, and social concern, including
                                                       Townsend's big-eared bat (Corynorhinus
Endangered Species Act
                                                       townsendii), pygmy rabbit (Brachylagus
   The purposes of the Endangered Species              idahoensis), burrowing owl (Speotyto
Act are to provide a means whereby the                 cunicuilaria), sage grouse (Centrocercus
ecosystems upon which endangered                       urophasianus), elk (Cervus elaphus), and
species and threatened species depend                  pronghorn        antelope    (Antilocapra
may be conserved; to provide a program for             americana).
the conservation of such endangered
                                                       Emergency Planning and Community
species and threatened species; and to take
                                                       Right-to-Know Act
such steps as may be appropriate to
achieve the purposes of the international                  The purpose of the Emergency Planning
treaties and conventions on threatened and             and       Community     Right-to-Know    Act
endangered species. It requires that all               (EPCRA) is to provide the public with
Federal departments and agencies shall                 information about hazardous chemicals at a
seek to conserve endangered species and                facility (such as the INEEL) and to establish
threatened species and shall utilize their             emergency planning and notification
authorities in furtherance of the purposes of          procedures to protect the public from
this Act.                                              chemical releases. EPCRA also contains
                                                       requirements for periodic reporting on
                                                       hazardous chemicals stored and/or used at


                                                 2-6
                                                       Chapter 2: Environmental Compliance Summary


a facility. Executive Order 13148, "Federal            Seven reports were prepared at the INEEL
Compliance with Right-to-Know Laws and                 during 2000.        These reports were for
Pollution     Prevention       Requirements,"          dioxins/dioxin-like compounds, nitric acid,
requires all federal facilities to comply with         nitrates, naphthalene, mercury/mercury
the provisions of EPCRA.                               compounds, toluene, and mixed isomer
                                                       xylenes. The 313 reports vary year-to-year
311 Report
                                                       depending on the chemical processes at the
   EPCRA Section 311 reports were                      Site. It is anticipated that fewer 313 reports
submitted quarterly for those chemicals that           will be completed in the future because of
met the reporting threshold. These reports             the Waste Experimental Reduction Facility
were sent to local emergency planning                  (WERF) incinerator shutdown and cessation
committees,     the     State    Emergency             of calciner operations.
Response Commission, and to local fire
departments for each quarter in calendar               Natural Resource Trusteeship and
year 2000. These quarterly reports satisfied           Natural Resources Damage Assessment
the 90-day notice requirement for new                      Executive Order 12580, Section 2(d),
chemicals brought onsite.                              appoints the Secretary of Energy as the
312 Report                                             primary Federal Natural Resource Trustee
                                                       for natural resources located on, over, and
    Local and State planning and response
                                                       under land administered by DOE. Natural
agencies received the Emergency and
                                                       resource trustees act on behalf of the public
Hazardous Chemical Inventory (Tier II)
                                                       when natural resources may be injured,
Report for 2000 by March 1, 2001. This
                                                       destroyed, lost, or threatened as a result of
report identified the types, quantities, and
                                                       the release of hazardous substances. In the
locations of hazardous and extremely
                                                       case of the INEEL, other natural resource
hazardous chemicals stored at INEEL
                                                       trustees with jurisdiction over trust
facilities that exceeded:
                                                       resources are the state of Idaho, U.S.
•   10,000 pounds (for Occupational Safety             Department of Interior (Bureau of Land
    and Health Act hazardous chemicals);               Management and the U.S. Fish and Wildlife
•   500 pounds (for Extremely Hazardous                Service), and the Shoshone-Bannock
    Substances as defined in 40 CFR 355);              Tribes.
    or                                                     Past releases of hazardous substances
•   the Threshold Planning Quantity,                   resulted in the INEEL's placement on the
                                                       National Priorities List.     These same
whichever is less.                                     releases created the potential for injury to
313 Report                                             natural resources. DOE is liable under
                                                       CERCLA for damages to natural resources
    The Toxic Chemical Release Inventory               resulting from releases of hazardous
Report was transmitted to the EPA and the              substances to the environment.          The
state of Idaho by July 1, 2001. The report             Environmental      Restoration     Program
identifies quantities of 313 listed toxic              coordinates with DOE-ID co-trustees on any
chemicals that exceeded a threshold value.             INEEL     Natural    Resources     Damage
Once a threshold value is exceeded (for                Assessment issues arising as a result of the
manufacturing, processing, or other uses),             comprehensive RI/FS study for each WAG.
an EPA 313 Form R report must be
completed for each specific chemical.                      Although the ecological risk assessment
These reports describe how the chemical is             is a separate effort from the Natural
released to the environment. Releases                  Resources Damage Assessment, it is
under EPCRA reporting include transfers to             anticipated that the ecological assessment
offsite waste storage and treatment, air               performed for CERCLA remedial actions
emissions, recycling, and other activities.            can be used to help resolve natural


                                                 2-7
2000 Annual Site Environmental Report


resource issues. Executive Order 12580                 requirements of International Standards
allows for this substitution [Reference 2-4].          Organization (ISO) 14001, an international
Ecological risk assessments at the INEEL               voluntary standard for environmental
have been conducted using the established              management systems. This standard is
guidance manual for conducting screening               being vigorously embraced worldwide and
level    ecological     risk    assessments            within the DOE complex. INEEL's goal for
[Reference 2-5].                                       certification under ISO 14001 demonstrates
                                                       continued      commitment    to   improved
Executive Order 11990 – Protection
                                                       environmental performance to regulators,
of Wetlands
                                                       the public, and the international business
     The Big Lost River Sinks are the only             community.
area of the INEEL identified as jurisdictional
                                                           An EMS provides an underlying
wetlands.      The U.S. Fish and Wildlife
                                                       structure to make the management of
Service National Wetlands Inventory map is
                                                       environmental activities more systematic
used to identify potential jurisdictional
                                                       and predictable. The EMS focuses on three
wetlands and nonregulated sites with
                                                       core    concepts:     pollution     prevention,
ecological, environmental, and future
                                                       environmental compliance, and continuous
development significance. Currently, there
                                                       improvement.        The primary system
are no identified operations at the INEEL
                                                       components are (1) environmental policy,
that have a significant impact on
                                                       (2) planning, (3) implementation and
jurisdictional wetlands.
                                                       operation, (4) checking and corrective
State of Idaho Wastewater Land                         action, and (5) management review.
Application Permits                                    DOE-ID is pursuing an EMS enhancement
    DOE-ID has applied for state of Idaho              development initiative for the Idaho
Wastewater Land Application Permits for all            workforce, and the M&O contractor is
existing land application facilities, and              working on a parallel effort for the INEEL.
permits have been issued for the Central                 In 2000, efforts continued on schedule
Facilities Area (CFA) Sewage Treatment                 toward implementing the elements of the
Plant, INTEC Percolation Ponds, INTEC                  EMS based on the ISO 14001 standard, in
Sewage        Treatment      Plant,    and             support of the contractual requirement to
TAN/Technical Support Facility (TSF)                   achieve ISO 14001 registration by June
Sewage Treatment Plant. The Idaho DEQ is               2002. Specific actions taken include:
reviewing permit applications for the Water
                                                       •   Completion of an overall project plan for
Reactor Research Test Facility Sewage and
                                                           ISO 14001 registration;
Process Ponds at TAN, the Naval Reactors
Facility (NRF) Industrial Waste Ditch, and             •   Issuance of an improved, more
the Argonne National Laboratory-West                       comprehensive INEEL environmental
(ANL-W) industrial and sanitary waste                      management policy;
ponds.     A land application permit was
                                                       •   Successful integration of environmental
submitted for the new INTEC percolation
                                                           protection into the Integrated Safety
ponds in January 2000.
                                                           Management System (ISMS) and
                                                           completion of all ISMS milestones
 2.2 ENVIRONMENTAL MANAGEMENT
                                                           related to the implementation of the
              SYSTEM
                                                           INEEL EMS;
     DOE-ID and the INEEL M&O contractor               •   Updates      to    strengthen    INEEL
continued to make progress on the effort                   documents to ensure full integration of
initiated in 1997 to develop and implement                 environmental requirements flow-down
an INEEL-wide Environmental Management                     into the work planning processes used;
System (EMS). The EMS will meet the


                                                 2-8
                                                       Chapter 2: Environmental Compliance Summary


•    Development of a communication plan               •   Matching the level of investigation to the
     for ISO 14001 registration;                           level of complexity of each release site.
•    Consolidation      of      functional                 Since the FFA/CO was signed in
     Environmental Safety and Health                   December 1991, the INEEL has cleaned up
     support services in order to provide              sites containing asbestos, petroleum
     efficiency; and                                   products, acids and bases, radionuclides,
                                                       unexploded ordnance and explosive
•    Increased emphasis on incorporating
                                                       residues, PCBs, heavy metals, and other
     pollution prevention and environmental
                                                       hazardous        wastes.      The   INEEL
     protection within the ISMS and
                                                       Environmental Restoration Program has
     environmental awareness programs.
                                                       maintained       significant progress    in
    This effort is being developed in concert          accomplishing its goals. As of December
with the ISMS and quality initiatives                  2000, a tally of environmental restoration
currently being implemented by DOE-ID and              activities at the INEEL showed:
the M&O contractor. Both the EMS and
                                                       •   Twenty-six   areas     for   conducting
ISMS are based on the "plan, do, check,
                                                           environmental investigations have been
act" concept, and they both involve work
                                                           identified;
planning, analysis of hazards and impacts,
operational     controls,   feedback,    and           •   Twenty-one environmental investigations
continuous improvement. DOE-ID and the                     have been completed;
M&O contractor already have in place many
                                                       •   Twenty-one RODs have been signed;
ISMS and EMS components. However,
links can be improved and redundancies                 •   Nine areas have cleanup underway; and
can be minimized. A primary goal of both               •   Twelve areas have completed cleanup.
DOE-ID and the M&O contractor is for work
planning and execution to proceed with full                Comprehensive RI/FSs have been
consideration of environmental, safety, and            completed for WAGs 1, 2, 3, 4, 5, 8, and 9.
health objectives and targets.                         Only WAGs 7 and 10 have ongoing RI/FS
                                                       efforts. The comprehensive RI/FSs, which
    2.3 ENVIRONMENTAL RESTORATION                      take an average of 40 months to complete,
                PROGRAM                                accomplish the following:
                                                       •   Determine the cumulative risks for an
Overview
                                                           entire WAG by assessing the combined
     In 2000, streamlining environmental                   impact of all release sites within that
restoration activities at the INEEL by DOE,                group;
the EPA, and the state of Idaho has saved
                                                       •   Review assumptions used in each
millions of dollars when compared to
                                                           previous investigation, including "No
original    baseline    estimates.        This
                                                           Further Action" sites, Track 1 and 2
streamlining was possible due to the
                                                           limited field investigations, RI/FSs, and
flexibility and management principles
                                                           interim actions;
established under the FFA/CO.             This
streamlining includes such activities as:              •   Identify data gaps and recommend
                                                           actions, such as field sampling or
•    Making cleanup decisions as soon as
                                                           historical document research, to resolve
     sufficient data are present;
                                                           questions;
•    Using existing data whenever possible;
                                                       •   Perform feasibility studies to evaluate
•    Avoiding duplication of analyses and                  remedial alternatives for the entire
     documentation; and                                    WAG;




                                                 2-9
2000 Annual Site Environmental Report


•   Develop proposed plans presenting the                and treat unit that uses air strippers and
    alternatives and recommending a                      filters to remove contaminants. More than
    preferred alternative; and                           98 million L (26 million gal) of contaminated
                                                         groundwater was treated in 2000.
•   Develop RODs selecting the alternative
    and resolving public comments.                             In 1999, new innovative technologies,
                                                         such as in-situ bioremediation and in-situ
    The     general   procedure    for   all
                                                         chemical oxidation, were evaluated to
comprehensive investigations begins with
                                                         determine if there was a more effective
developing a work plan outlining potential
                                                         technology than pump and treat.            The
data gaps and release sites that may
                                                         evaluation        showed        that    in-situ
require more field sampling. When the
                                                         bioremediation was a better alternative for
investigation is complete, DOE, EPA and
                                                         the area around the old injection well (also
the State hold public comment meetings on
                                                         called the “hot spot”), and that monitored
the proposed cleanup alternative. Only four
                                                         natural attenuation was a better alternative
investigations remain to be completed:
                                                         for the distal portion of the plume. The
1. Buried waste at the RWMC;                             evaluation showed that pump and treat was
2. Soil contamination at the INTEC Tank                  still the best alternative for the medial zone
   Farm;                                                 of the plume. As a result, a Proposed Plan
                                                         was distributed for public comment
3. Miscellaneous sites, including EBR-I/                 proposing that the remedy be changed to in
   Boiling Water Reactor Experiment-I; and               situ bioremediation at the hot spot and
4. Snake      River        Plain        Aquifer          monitored natural attenuation in the distal
   contamination.                                        zone. Pump and treat would remain the
                                                         technology for the medial zone.
Waste Area Group 1 – Test Area
North                                                    Waste Area Group 1 – Comprehensive
                                                         RI/FS
Waste Area Group 1 – Groundwater                             Eleven operable units, including tanks
Remediation                                              containing      PCBs,      hazardous,    and
    Cleanup of the TAN injection well began              radioactive wastes (the V-tanks), were
in 1993. The well was used from 1953 until               evaluated during the final investigation. A
1972 to inject liquid wastes into the                    ROD for the comprehensive investigation
fractured basalt of the Snake River Plain                was signed at the end of 1999.
Aquifer. The wastes included organic and                 Remediation began at eight contaminated
inorganic    compounds     and    low-level              sites identified in the ROD. By the end of
radioactive wastes (LLW) combined with                   2000, 532 m3 (696 yd3) of contaminated soil
industrial and sanitary wastewaters. The                 had been packaged and shipped to the
resulting plume contaminated some of the                 RWMC for disposal.          Another 761 m3
drinking water wells used by TAN workers.                (995 yd3) of contaminated materials was
The drinking water is treated to meet                    sent offsite for disposal.
drinking water standards, and untreated
groundwater is not accessible to workers or              Waste Area Group 2 – Test Reactor Area
the public.                                              Waste Area Group 2 – Perched Water
    The TAN groundwater final remedial                   System
action ROD was approved in August 1995.                      Perched water under the Test Reactor
The Groundwater Treatment Facility,                      Area (TRA) is a zone of groundwater
designed and constructed under a 1994                    standing on a relatively impermeable layer
interim action, has been in continuous                   of clay 100 m (330 ft) above the Snake
operation since November 1996.       The                 River Plain Aquifer. It was formed over time
Groundwater Treatment Facility is a pump                 by percolation from the TRA wastewater



                                                  2-10
                                                        Chapter 2: Environmental Compliance Summary


disposal ponds.        Routine compliance               complete, a separate ROD will be prepared
monitoring continued in 2000 to aid                     to detail cleanup actions.
regulatory agencies in comparison of
                                                            Workers began an interim action to
predicted    and      actual   contaminant
                                                        prevent the percolation of water, from
concentrations in the perched water.
                                                        precipitation, into the Tank Farm. The
Waste Area Group 2 – Newly Identified                   barrier is scheduled to be completely
Sites                                                   installed in 2001.
    Six potentially contaminated sites were             Waste Area Group 3 – New Wastewater
identified since the original RI/FS report.             Disposal Ponds.
These sites contain either contaminated
                                                            One of the actions under the approved
soils,    abandoned      underground   acid
                                                        ROD for WAG 3 is to reduce contributions
pipelines, or abandoned underground fuel
                                                        to perched water beneath the INTEC that
oil pipelines. These sites are scheduled to
                                                        might be contributing to contaminant
be investigated further in 2001.
                                                        migration. A large part of this task includes
Waste Area Group 2 – Comprehensive                      curtailment of the use of the current
RI/FS                                                   wastewater disposal ponds (percolation
    In 2000, remediation was completed at               ponds).       Construction of two new
eight sites identified in the 1997 ROD. Sites           percolation ponds, at a distance of almost
included the Warm Waste Pond, Chemical                  3.2 km (2 mi) from the facility, began in
Waste Pond, and Sewage Leach Pond.                      August 2000. The ponds are scheduled for
Cleanup actions at the three ponds                      completion in 2001 and to be put into
consisted of covering them with intrusion               service in 2002.
resistant soil barriers, implementation of                  Instruments are being installed around
institutional controls for access, and use              the new ponds to allow scientists to observe
restrictions to protect current and future              water movement in the vadose zone as the
users.     Some of the remediated sites,                ponds fill. The understanding gained from
totaling almost 3.2 hectares (8 acres), were            this work will be applied to other areas
replanted.                                              across the INEEL.
Waste Area Group 3 – Idaho Nuclear                      Waste Area Group 3 – INEEL CERCLA
Technology and Engineering Center                       Disposal Facility.
Waste Area Group 3 – Tank Farm                              The INEEL CERCLA Disposal Facility
    The RI/FS to investigate contaminated               (ICDF) was selected as a remedy in the
soils and the aquifer beneath the INTEC                 1999 ROD for INTEC to address Sitewide
Tank Farm began in 2000. The Tank Farm                  soil contamination. The purpose of the
consists of 20 underground stainless steel              facility is to consolidate INEEL wastes
tanks, and associated equipment for waste               generated from CERCLA cleanup actions at
transfer, used to store the radioactive liquid          a single engineered facility onsite. In 2000,
waste generated during the reprocessing of              geologic studies at INTEC were used to
spent fuel. Approximately 95 percent of the             select a location for construction of the
existing environmental contamination at the             ICDF.      Construction on the facility is
Tank Farm is the result of leakage from                 expected to begin in 2001, with operations
transfer lines and piping.       The tanks              expected to commence in 2003.
themselves have not leaked.               This          Waste Area Group 3 – Comprehensive
investigation will gather information on the            RI/FS
distribution, quantities, and concentrations
                                                            The major source of contamination at
of contaminants associated with the Tank
                                                        INTEC is HLW generated from past spent
Farm soil. Once the investigation phase is
                                                        nuclear fuel (SNF) reprocessing activities
                                                        that is stored in underground storage tanks.


                                                 2-11
2000 Annual Site Environmental Report


The      Site   also    has    contaminated            would fall below the drinking water standard
groundwater from a now sealed injection                by 2009. DOE, EPA, and the State agreed
well, contaminated soils around and                    that no further action was necessary to
beneath buildings, and waste disposal                  address this contamination issue.
ponds. The chief contaminants are
                                                       Waste Area Group 5 – Power Burst
radionuclides. A total of 101 sites of known
                                                       Facility/Auxiliary Reactor Area
or suspected contaminant releases were
evaluated in the comprehensive RI/FS                   Waste Area Group 5 – Comprehensive
(December 1997) and summarized in a                    RI/FS
Proposed Plan (October 1998). Sixty-six of                 The comprehensive RI/FS report was
the 101 sites require cleanup; the majority            published in 1999. This report covered
of these sites were addressed in the ROD               13 operable units and 55 potential release
finalized in October 1999.                             sites. Contaminants include heavy metals,
    The ROD also included a large, onsite              radionuclides, and organic chemicals
disposal facility at INTEC for cleanup-                originating     from    such sources     as
related waste from INEEL (see previous                 underground tanks, hot cells, waste
discussion of the ICDF). DOE, EPA, and                 disposal ponds, a sewage system, and
the State approved remedial action work                buried reactor debris. The comprehensive
plans for the Tank Farm Interim Action,                investigation identified seven sites that
Perched Water, and Snake River Plain                   require cleanup: three evaporation ponds, a
Aquifer. Remedial actions were begun in                large contaminated surface soil area, soil
2000 for the Tank Farm Interim Action,                 beneath now dismantled hot cells, a
Perched Water, Snake River Plain Aquifer,              sanitary waste system, and an underground
and Gas Cylinder sites.                                storage tank. The remaining 48 sites require
                                                       no remediation and will remain under
Waste Area Group 4 – Central Facilities                institutional controls.
Area
                                                           A proposed plan based on the RI/FS
Waste Area Group 4 – Comprehensive                     was published in 1999 and describes the
RI/FS                                                  risks associated with the seven sites,
    A total of 13 operable units and 52                possible remediation alternatives, and
potential release sites were examined                  preferred alternatives.  Following public
during this investigation. The main sources            comment on the proposed plan, a final ROD
of contamination are landfills, a waste                was signed in February 2000.
disposal pond, a wastewater drain field, and
                                                           Remediation began in June 2000 on the
underground storage tanks.             Major
                                                       sanitary waste system and tank and three of
contaminants are metals, radionuclides, and
                                                       the    five   contaminated    soils   sites.
nitrates. A final ROD for the CFA was
                                                       Approximately 60 m3 (78 yd3) of debris was
signed July 2000 addressing surface
                                                       removed for disposal offsite. Remediation
contamination at three sites, including a
                                                       of the largest soil site (23.5 hectares
now dry waste disposal pond, a sewage
                                                       [58 acres]) will be coordinated with
treatment plant drain field, and a
                                                       completion of the ICDF, where the soil will
transformer yard. These three areas will be
                                                       be disposed.
remediated one site at a time, beginning
with the transformer yard.
    The comprehensive RI/FS was near
completion in 1999 when nitrates were
detected in one well in the area in excess of
drinking water standards. During 2000,
analysis of monitoring data and computer
modeling indicated that levels of nitrates


                                                2-12
                                                       Chapter 2: Environmental Compliance Summary


Waste Area Group 6 – Boiling Water                          The first stage of the staged interim
Reactor Experiment                                     action will provide information on specific
                                                       subsurface conditions, including whether,
Waste Area Group 6 – Comprehensive
                                                       how far, and which contaminants have
RI/FS
                                                       migrated. This information is necessary to
    This comprehensive investigation is                support the transport modeling and baseline
being conducted in combination with the                risk assessment activities for WAG 7.
WAG 10 comprehensive RI/FS.                            Stage I will also include a limited treatment
Waste Area Group 7 – Radioactive Waste                 technology evaluation. Stage II activities
Management Complex                                     include construction, soil treatment studies,
                                                       and retrieval of buried material from an area
Waste Area Group 7 – Remedial Action of                of the pit selected during Stage I. Stage III
Organic Contamination in the Vadose Zone               will complete the remediation of Pit 9.
    The ROD to use the vapor vacuum
extraction with treatment as the remediation               In 2000, Stage I investigations included
technology for the vadose zone in the                  installation of 85 probes within Pit 9 and
Subsurface Disposal Area (SDA) at the                  other areas of the SDA. The probes are
RWMC became final on December 2, 1994.                 15-cm (6-in.) diameter hollow steel tubes.
The vadose zone is the area between the                Probes were installed using sound waves (a
land surface and the top of the water table.           method known as sonic drilling) to advance
Organic vapors were released into the                  the probe through the waste to the top of
vadose zone as buried drums containing                 the underlying basalt. Data gathered from
volatile organic compounds, such as                    geophysical instruments placed in the probe
degreasers and solvents, deteriorated over             tubes provide vertical waste and soil profile
time.                                                  information,    apparent    distribution   of
                                                       contaminants, and identification of localized
    The    full-scale   extraction/treatment           areas of radionuclide contamination. In
system consists of three treatment units that          addition, the Stage I 90 percent design was
extract vapors from three wells and break              also completed in 2000.
down the majority of organic compounds
chemically to form carbon dioxide, hydrogen            Waste Area Group 7 – Comprehensive
chloride, and water. The system began                  RI/FS
operations in January 1996 and as of 2000                  The work plan addendum, detailing how
over 37,195 kg (82,000 lb) of total volatile           the comprehensive investigation will be
organic compounds have been removed                    performed, was finalized in August 1998.
from the vadose zone. The system will                  The addendum reflects schedule and scope
continue to extract and treat organics from            changes that resulted from significant
the SDA in 2001.                                       delays in the Pit 9 interim action, and it
                                                       describes additional scope to be completed.
Waste Area Group 7 – Pit 9 Interim Action              These changes will allow DOE to evaluate a
    The staged interim action, a three-stage           wider range of remedial alternatives for the
approach agreed to by the DOE, EPA, and                buried waste, including several treatability
the State, has two main objectives:                    studies, in support of pit and trench
1. Remediate contamination to a level that             remedial options.
   protects human health and the                           In 2000, a treatability study of the in-situ
   environment; and                                    grouting of buried transuranic (TRU) waste
2. Generate information to support the                 was performed. Because it is done in place,
   RI/FS and the final remedial decision for           this process has the advantages of low cost
   the RWMC SDA.                                       and low worker exposure.
                                                          Groundwater and perched water
                                                       samples continue to be collected quarterly


                                                2-13
2000 Annual Site Environmental Report


in and around the RWMC to assess                         these two sites was performed in 2000 with
potential migration of contaminants from the             the excavation and disposal of 69 m3
site.                                                    (90 yd3) of soil from these sites.
Waste Area Group 8 – Naval Reactors                          At WAG 9, phytoremediation involves
Facility                                                 using koscia and willows to extract
                                                         contaminants. The plants are periodically
Waste Area Group 8 – Naval Reactors
                                                         harvested, dried, packaged, and disposed
Facility Remediation
                                                         at    an     appropriate     facility.      The
    DOE, EPA, and the state of Idaho                     phytoremediation project began in 1999 and
signed a ROD for 10 sites at NRF in 1994.                continued through 2000.              Results of
Three of these sites were landfills that were            analysis on plants at the end of the second
capped with native soil covers in 1996. The              year showed that contaminants of concern
agencies agreed the other sites (the                     should meet risk levels by the 6-year
industrial waste ditch and six other landfills)          deadline. Also in 2000, willows that had
required no further action. Remediation                  been growing in three industrial waste
continued in 2000 at the nine sites of                   ditches were harvested. Willows are used
concern, including completion of remedial                to extract chromium, silver, and mercury
actions at one site.                                     from the soil. Analysis of the plant matter
Waste Area Group 8 – Comprehensive                       showed the willows extracted significant
RI/FS                                                    amounts of these metals from the soil. New
    A ROD for the comprehensive                          trees will be planted in the spring of 2001 for
investigation of the NRF was signed in                   another 2-year growing cycle.
September 1998. It addressed 64 sites,                   Waste Area Group 10 – Miscellaneous
including    9   sites     with    potentially           Sites/Snake River Plain Aquifer
unacceptable risk to human health or the
                                                         Waste Area Group 10 – Comprehensive
environment.       Fifty-five sites were
                                                         RI/FS
determined to not require additional actions.
Remediation continued in 2000 at the nine                    This comprehensive investigation will
sites of concern, including completing                   address WAG 6 and 10 sites and the Snake
remedial actions at one site. The effort                 River Plain Aquifer, as well as conducting
includes excavating and consolidating soils              the Sitewide ecological risk assessment,
contaminated     with     low    levels    of            collectively referred to as Operable Unit
radionuclides.                                           10-04. A new Operable Unit, 10-08, was
                                                         created in 1999 to evaluate new
Waste Area Group 9 – Argonne National                    contamination release sites that may be
Laboratory-West                                          identified at the INEEL in the future and to
Waste Area Group 9 – Comprehensive                       perform a Sitewide cumulative groundwater
RI/FS                                                    assessment. The comprehensive Sitewide
    In 1998, DOE, EPA, and the state of                  ecological risk assessment was completed
Idaho      signed       the    comprehensive             in 2000. The results of this assessment will
investigation ROD for ANL-W, which                       be included in a Proposed Plan scheduled
identified five sites requiring cleanup. The             for completion in 2001.            Additional
ROD identified phytoremediation (the use of              groundwater monitoring wells were drilled in
plants to extract contaminants through their             2000 to improve understanding of
root systems) as the preferred method for                contaminant movement within the aquifer.
removing contaminants from the soil at                       A comprehensive investigation of
these five sites, except for portions of two             contaminated land surface areas within the
sites. These two sites have additional                   INEEL was completed in 2000.            This
contamination on which phytoremediation                  investigation encompassed impacts of
would not be effective. Remediation of                   INEEL activities upon surface water, surface


                                                  2-14
                                                        Chapter 2: Environmental Compliance Summary


soils, and air. The investigation included all          mission and accomplishments of the Waste
areas outside facility fences as well as the            Management Program.
EBR-I/Boiling Water Reactor Experiment
                                                        Federal Facility Compliance Act
area.
                                                            The Federal Facility Compliance Act
    2.4 WASTE MANAGEMENT PROGRAM                        requires the preparation of site treatment
                                                        plans for the cleanup of mixed wastes
Overview                                                (those containing both radioactive and
    The mission of the Waste Management                 nonradioactive hazardous materials) at the
Program at the INEEL is to provide safe,                INEEL.      The INEEL Proposed Site
compliant, and cost-effective management                Treatment Plan was submitted to the state
services for facility waste streams. Safe               of Idaho and EPA on March 31, 1995.
operations and compliance with federal,                 Copies of the plan were also sent to various
State, and local regulations are the highest            reading rooms throughout Idaho, the INEEL
priorities    along    with  meeting     the            Citizens Advisory Board, and the Shoshone-
commitments made in the Idaho Settlement                Bannock Tribes.        This plan outlined
Agreement and the INEEL Site Treatment                  DOE-ID's proposed treatment strategy for
Plan. The goals of the program are to                   INEEL mixed waste streams, called the
ensure that workers and the public are                  “backlog,” and provided a preliminary
protected and the environment is not further            analysis of potential offsite mixed low-level
impacted.       INEEL waste management                  waste (LLW) treatment capabilities.
activities consist of:                                       The INEEL Proposed Site Treatment
•    Reducing the total amount of wastes                Plan formed the basis for negotiations
     generated;                                         between the state of Idaho and DOE-ID on
                                                        the consent order for mixed waste treatment
•    Treating wastes already generated by               at the INEEL.        The Federal Facility
     reducing their toxicity, mobility, and             Compliance Act consent order and Site
     volume;                                            Treatment Plan were finalized and signed
•    Storing wastes awaiting development of             by the state of Idaho on November 1, 1995.
     new disposal and treatment options; and            Two changes to the administrative sections
                                                        of the plan were negotiated to resolve
•    Disposing of wastes.                               issues between the State and DOE-ID: (1)
    Another challenge faced in managing                 DOE reserved its right to challenge the
wastes at the INEEL is involving the citizens           approval authority of the State over offsite
of Idaho in the search for solutions to                 wastes and (2) both parties agreed to
significant waste management issues. The                immediately modify the plan's schedules to
Waste Management Program continues to                   be      consistent  with the Settlement
provide presentations to the INEEL Citizens             Agreement and court order issued in
Advisory Board to explain issues related to             October 1995 in the Spent Nuclear Fuel and
the program. The Waste Management                       INEEL Environmental Impact Statement
Program continues to promote openness                   litigation.
with stakeholders in regard to these issues                 In accordance with the Site Treatment
and works closely with the State INEEL                  Plan, the INEEL began receiving offsite
Oversight Program and the Congressional                 mixed waste for treatment in January 1996.
delegation. Stakeholders were also notified             The INEEL has received mixed waste from
of the timeframes for regulatory-required               other sites within the DOE complex
public comment periods and where                        including Hanford, Los Alamos, Paducah,
documents could be found for their review.              Pantex, Sandia, and six locations managed
In addition, stakeholders participated in               by the Office of Naval Reactors.      The
several tours of the INEEL that featured the            INEEL stopped receiving offsite mixed


                                                 2-15
2000 Annual Site Environmental Report


waste for treatment at the WERF in 2000.                  transuranic waste by 2015, but no later than
The INEEL is storing the backlog of mixed                 2018.
waste at the Waste Reduction Operations
                                                          Sodium     Process   Facility  and
Complex (WROC) and INTEC RCRA-
                                                          Experimental    Breeder   Reactor-II
permitted storage. Disposal of the backlog
                                                          Sodium Removal and Treatment
mixed waste will occur by no later than
                                                          Activities
2006.
                                                             The Sodium Process Facility (SPF) at
    Treatment of the majority of the offsite
                                                          ANL-W continued treatment of radioactive
waste was performed at the WROC using
                                                          sodium stored at ANL-W. SPF treated
incineration, stabilization, neutralization, and
                                                          178,274 L (47,095 gal) of sodium in 2000.
carbon absorption technologies. Additional
treatment services will be obtained from                  High-Level Waste        and    Facilities
offsite commercial treatment vendors.                     Disposition
Other offsite mixed wastes may be treated                     In 1953, reprocessing of spent nuclear
at the Advanced Mixed Waste Treatment                     fuel began at the INTEC, resulting in the
Facility planned to begin operation at the                generation of high-level waste (HLW),
INEEL in 2003.                                            including radioactive liquid waste and
Advanced Mixed Waste Treatment                            sodium-bearing liquid waste (SBW). Those
Project                                                   wastes were placed into interim storage in
                                                          underground tanks at the INTEC Tank Farm
    The overall goal of the Advanced Mixed
                                                          Facility. Treatment of those wastes began
Waste Treatment Project is the treatment of
                                                          in 1963 through a process called calcining.
alpha low-level mixed and TRU wastes for
                                                          The resultant waste form, known as calcine,
final disposal, by a process that minimizes
                                                          was placed in storage in stainless steel
overall costs while ensuring safety. This will
                                                          bins, known as bin sets, at the Calcine
be accomplished through a private sector
                                                          Solids Storage Facility. Processing of spent
treatment facility with the capability to treat
                                                          nuclear fuel was curtailed in 1992. The
specified INEEL waste streams and the
                                                          INEEL completed calcining of all non-
flexibility to treat other INEEL and DOE
                                                          sodium-bearing liquid HLW on February 20,
regional and national waste streams. The
                                                          1998, four months ahead of the June 30,
services will treat waste to meet the most
                                                          1998      Idaho   Settlement     Agreement
current requirements, reduce waste volume
                                                          milestone. Calcining of SBW began on
and life-cycle cost to DOE, and perform
                                                          February 20, 1998, more than three years
tasks in a safe, environmentally compliant
                                                          ahead of the Settlement Agreement
manner.
                                                          milestone. Per that Agreement, all such
   A contract for treatment services was                  waste is required to be calcined by the end
awarded to BNFL, Inc. in December 1996.                   of the year 2012.
The contract was awarded in three phases:
                                                               During 2000, 90,000 L (23,775 gal) of
•   Phase I — licensing, permitting and                   SBW were calcined prior to the Calciner
    environmental compliance;                             being placed in standby. Therefore, at the
                                                          end of 2000, approximately 4,500,000 L
•   Phase II — construction and process
                                                          (1,188,774 gal) of SBW in the tank farm,
    demonstration to be completed in
                                                          and 4,400 m3 (5,755 yd3) of calcined HLW
    December 2002;
                                                          in the bin sets, remains in storage at INTEC.
•   Phase III — treatment operations to                   The calciner was placed in standby prior to
    begin by March 2003.                                  the extended deadline of June 1, 2002 per
   The facility is scheduled to treat                     the 1999 Modification to Notice of
65,000 m3 (85,017 yd3) of retrievably stored              Noncompliance Consent Order, while DOE
                                                          determines whether to upgrade and permit



                                                   2-16
                                                        Chapter 2: Environmental Compliance Summary


the facility to current standards or develop a          Pollution Prevention Requirements), and
new method of treating the stored liquid                Executive Order 12873 (Federal Acquisition,
HLW.        Treatment alternatives for the              Recycling, and Waste Prevention).
remaining liquid and calcined wastes are
                                                            It is the policy of the INEEL to
being evaluated in the Idaho High-Level
                                                        incorporate pollution prevention into every
Waste         and     Facilities   Disposition
                                                        activity. Pollution prevention is one of the
Environmental Impact Statement.
                                                        key      underpinnings   of    the    INEEL
Low-Level Radioactive Waste and                         Environmental Management System (see
Mixed Low-Level Radioactive Waste                       Section 2.2). It functions as an important
                                                        preventive mechanism because generating
    Significant   accomplishments     were
                                                        less waste reduces waste management
achieved during 2000 in the disposal of the
                                                        costs, compliance vulnerabilities, and the
legacy backlog of LLW stored at the INEEL.
                                                        potential for releases to the environment.
Activities at the RWMC SDA were
                                                        The INEEL is promoting the inclusion of
highlighted by the disposal of 4,535 m3
                                                        pollution prevention into all planning
(5,932 yd3) of legacy and newly generated
                                                        activities as well as the concept that
LLW in 2000.
                                                        pollution prevention is integral to mission
    WROC treated 3,071 m3 (4,018 yd3) of                accomplishment.
LLW. Two cubic meters of mixed LLW were
                                                            In 2000, the INEEL reported 23 pollution
stabilized at the WERF.         The WERF
                                                        prevention projects, which resulted in a
                            3
incinerator treated 193 m (252 yd3) of
                                                        waste reduction of 10,810 m3 (14,139 yd3)
mixed LLW. The WERF incinerator was
                                                        and decreased the cost of operations by
shut down in September 2000 because
                                                        $31.9 million.       Noteworthy pollution
DOE decided to use commercially available
                                                        prevention accomplishments in 2000
mixed waste treatment facilities and
                                                        include
because the Idaho DEQ denied the final
RCRA Part B permit application. During its              •   INEEL     Environmental       Restoration
operation,      the   incinerator     treated               personnel      are      decontaminating,
approximately 12,000 m3 (15,695 yd3) of                     decommissioning,      and     dismantling
LLW and more than 1,000 m3 (1,308 yd3) of                   buildings and equipment and are
mixed LLW from both INEEL and other                         reusing/recycling the resulting concrete,
facilities.   Also, approximately 470 m3                    steel, water, and wood materials,
            3
(615 yd ) of mixed LLW was sent to                          reducing sanitary waste by 5,262 metric
Envirocare in Utah for disposal in 2000.                    tons (5,800 tons) and saving almost $9
                                                            million.
    The goals for 2001 include the treatment
of 150 m3 (196 yd3) of mixed LLW and                    •   The INTEC coal-fired steam plant was
disposal of 400 m3 (523 yd3) of mixed LLW                   shut down and replaced with oil-fired
offsite.                                                    boilers, saving just over $8 million.
                                                            Approximately 2,630 kg (5,800 lb) of
Waste Minimization/Pollution Prevention
                                                            hydrogen chloride, hydrogen fluoride,
    The mission of the INEEL Pollution                      hydrogen sulfate, chromium, and zinc
Prevention Program is to reduce the                         air emissions was eliminated, as well as
generation and release of wastes and                        ash output of 430 metric tons (474 tons).
pollutants by implementing cost-effective
                                                        Lead Management Program
pollution prevention techniques, practices,
and policies. Pollution prevention is also                The intent of the INEEL              Lead
required by various federal edicts, including           Management Program is to:
but not limited to, the Pollution Prevention
                                                        •   Minimize new lead purchases;
Act, RCRA, Executive Order 12856 (Federal
Compliance with Right-To-Know Laws and                  •   Evaluate lead substitutes;


                                                 2-17
2000 Annual Site Environmental Report


•   Maximize reuse of contaminated lead                have totaled $30 million and created nearly
    for shielding;                                     2,600 jobs.
•   Protect lead from contamination;                   Transuranic Waste
•   Reduce     the     accumulation        of              The TRU Program accomplished
    contaminated lead;                                 several major goals in 2000. The INEEL
                                                       completed 26 shipments to the Waste
•   Recycle contaminated lead to the scrap
                                                       Isolation Pilot Plant (WIPP) in Carlsbad,
    metal market (by decontamination and
                                                       New Mexico, for a total of 849 drums
    surface/volumetric survey for free
                                                       containing 177 m3        (232 yd3) of TRU
    release) as allowable; and
                                                       waste. A total of 3,100 m3 (4,056 yd3) of
•   Provide the means for generators to                stored TRU waste must be shipped to WIPP
    disposition mixed waste lead.                      by December 31, 2002, to meet a
    To date, 87.6 m3 (114.6 yd3) of waste              Settlement        Agreement     milestone.
have been processed through the cask                   Approximately 60 percent of DOE’s current
dismantlement activity, including 7 m3                 inventory of contact-handled TRU waste is
(9.1 yd3) in 2000 in accordance with the Site          stored at the RWMC.        The Settlement
Treatment Plan.                                        Agreement requires that all of INEEL’s
                                                       stored TRU waste, currently estimated at
Idaho Settlement Agreement                             about 64,700 m3 (84,628 yd3), must be
    On October 16, 1995, DOE, the U.S.                 shipped to WIPP by a target date of 2015
Navy, and the state of Idaho entered into an           but no later than 2018.
agreement that will guide management of
SNF and radioactive waste at the INEEL for                    2.5 ENVIRONMENTAL RISK
                                                                       REDUCTION
the next 40 years. The agreement makes
Idaho the only state with a federal court-
                                                       Decontamination, Decommissioning,
ordered agreement limiting shipments of
                                                       and Demolition Activities
DOE and Naval SNF into the State and
setting milestones for shipments of SNF and              Decontamination, decommissioning, and
radioactive waste out of the State. Both               demolition activities at the INEEL are
Settlement       Agreement       milestones            primarily concerned with the safe and
scheduled for 2000 were met as follows:                compliant        decontamination         and
                                                       decommissioning      (D&D)      of   inactive
•   Empty the south basin of CPP-603. The
                                                       facilities. These facilities fall under two
    milestone of December 31, 2000, was
                                                       broad categories: (1) structures potentially
    met on April 28, 2000, 8 months ahead
                                                       suitable for reuse and (2) structures not
    of schedule; and
                                                       suitable for reuse. In the last 4 years more
•   Receive no more than 20 Naval spent                than 100 buildings have been demolished.
    fuel shipments per year (1997—2000).               Specific projects at various facilities are
    Sixteen shipments were received in                 described below.
    2000.
                                                       Central Facilities Area
   As part of the Settlement Agreement,                    The CFA Sewage Treatment Plant
the state of Idaho received another                    served as the sewage treatment facility for
$6 million from DOE for economic                       CFA since 1944 with multiple upgrades.
development in eastern Idaho.        Idaho             D&D was started on the facility in October
awarded       grants    to    the  Regional            1996 and completed in February 2000. The
Development Alliance and State universities            D&D activities were focused on the removal
and     colleges     to   reduce  economic             of all existing structures, equipment, utility
dependence on the INEEL. Awards to date                components such as the pump-house, and
                                                       ancillary equipment.


                                                2-18
                                                      Chapter 2: Environmental Compliance Summary


Test Area North                                       technologies to make DOE’s D&D
    Demolition of the aboveground portion             operations more efficient through the use of
of the Initial Engine Test Facility was               better technologies.      Technologies are
completed in 2000. This facility was used             demonstrated in an actual D&D operation,
from the late 1950s through 1961 to test              side-by-side with baseline technology.
experimental jet engines for use in nuclear-          Three INEEL areas are included in the
powered aircraft. The remaining buildings             project: TRA-660 Fuel Storage Canals,
at this facility are being removed. The               TRA Filter Pit System, and TAN-620 Initial
engines themselves are on display near the            Engine Test Control Room. The following
EBR-I facility.                                       technologies were demonstrated in 2000:
    The Process Experimental Pilot Plant              •   En-Vac Robotic Climber with Scabbler;
incinerator located at TAN was designed to            •   In-Situ Object Counting System Far
process TRU waste into an acceptable form                 Field Release Radiation Measurement
to meet disposal requirements at WIPP.                    System;
The facility was only used one time. The
facility was decontaminated from June 1999            •   SAMS® Radiation Survey Instrument;
through March 2000 to an approved closure                 and
plan.                                                 •   In-Situ Underwater Gamma Survey
Test Reactor Area                                         Underwater Radiation Measurement
                                                          System.
   Decontamination and dismantlement of
the Continuous Aerosol Collection System              2.6 NATIONAL PROGRAMS MANAGED
Test Platform in TRA Building 654 was                               BY DOE-ID
completed in December 2000.
     Building 660 (TRA-660) at TRA, houses            Nuclear Materials Focus Area
two 100-kilowatt water-cooled nuclear                     The Nuclear Materials Focus Area
research reactors: the Advanced Reactivity            (NMFA) is chartered under the DOE Office
Measurement Facility reactor and the                  of Environmental Management to conduct a
Coupled Fast Reactivity Measurement                   research and development program to
Facility reactor. A NEPA Environmental                develop technologies to support the safe
Assessment (EA) was prepared to                       management and expeditious stabilization
determine whether there would be any                  of nuclear materials currently under the
significant      environmental      impacts           purview of the Office of Environmental
associated with D&D of the reactors and               Management.
whether an EIS would be necessary. Drafts
of the EA and finding of no significant                   NMFA is a multi-year, complexwide
impact (FONSI) were released for public               program that includes collaboration on
review and comment, and no comments                   technology ventures with Russian scientists
were received. The final EA and FONSI                 as part of the U.S.-Russian nonproliferation
were released in March 2000. The reactors             program. NMFA research and development
will be dismantled and disposed in 2001.              projects for 2000 include:
    The Engineering Test Reactor was                  •   Advanced Technologies for Stabilization
dismantled and removed in September                       of 238Pu-Contaminated Combustible
2000. The building it was housed in was left              Waste;
intact for potential future use.                      •   Porous Crystalline Matrix (Gubka) for
INEEL Large Scale Demonstration and                       Stabilizing Actinide Solutions;
Deployment Project                                    •   Chemically-Bonded            Phosphate
   The INEEL Large Scale Demonstration                    Ceramics;
and Deployment Project demonstrates


                                               2-19
2000 Annual Site Environmental Report


•   Modular Arm for Accelerated Plutonium             of Phase I allows the program to move on to
    Glovebox Operation; and                           greater challenges like mounting an
                                                      automated handling system on a mobile
•   Moisture Measurement in Pure and
                                                      platform for sites with small TRU waste
    Impure Plutonium Bearing Materials.
                                                      quantities.    In total, support for five
Transuranic and Mixed Waste Focus                     technology     demonstrations    and    six
Area                                                  technology deployments were completed at
    DOE-Headquarters       established    an          the various DOE sites.
integrated approach for addressing waste                  The Transuranic and Mixed Waste
issues based on focus or problem areas.               Focus Area was also in the forefront
The INEEL was selected as the lead                    supporting the Blue Ribbon Panel on
laboratory for mixed waste technology                 Emerging Technological Alternatives to
development. Comanaged by DOE-ID and                  Incineration and developing the DOE’s path
the DOE Carlsbad Field Office, the                    forward in this area.          Testing and
Transuranic and Mixed Waste Focus Area                demonstration of alternatives to incineration
operates in close partnership with end users          technologies will occur in the next few
and regulators to address and meet priority           years.        Significant  accomplishments
needs and ensure that demonstrated                    occurred in the area of payload
solutions are accepted and approved for               enhancement.       The TRUPACT-II Matrix
deployment.      DOE identified more than             Depletion Program report was submitted to
2,300 mixed waste streams at its sites,               the Carlsbad Field Office and will assist in a
including stored inventory and waste                  greater percentage of the current contact-
generated by ongoing processes and                    handled TRU/mixed TRU waste inventory
cleanup activities.                                   being certified for shipment to WIPP. The
    Several new developments have taken               program has and will continue to address
place in the past year. The program’s name            technology needs identified by the DOE
changed from the Mixed Waste Focus Area               sites for managing their waste issues.
to reflect the importance the DOE places on           National Spent Nuclear Fuel Program
ensuring uninterrupted, safe, and efficient
                                                           DOE-ID manages the National Spent
shipments of TRU waste from storage to the
                                                      Nuclear Fuel Program (NSNFP).           The
WIPP. Solutions were deployed for an
                                                      NSNFP mission is to provide the technology
array of mixed LLW debris and TRU waste
                                                      and guidance needed to ensure safe,
problems. The DOE’s waste operations
                                                      efficient handling, characterization, and
managers now have a quick, inexpensive
                                                      disposition of DOE SNF. In completing this
method for analyzing the chlorine content in
                                                      mission, the NSNFP, while working with
waste destined for treatment. They also
                                                      stakeholders, will protect the environment
have a new method for treating mixed LLW
                                                      and the health and safety of workers and
debris that results in a 25 percent volume
                                                      the public while fully complying with
reduction over conventional techniques.
                                                      applicable federal, state, Tribal, and local
Surrogates were also deployed for standard
                                                      laws, orders, and regulations.
waste boxes and crates, which were
needed at several sites for evaluating,                   The NSNFP provides technology
calibrating, and refining nondestructive              solutions and guidance for safe, efficient
crate/box assay systems. In addition, a               management at DOE SNF operating sites.
major technical milestone was met with the            It supports the repository program by
completion of Phase I of Handling and                 providing the analyses and research
Segregating System for 55-gal drums                   needed to include all DOE SNF in the
(HANDSS-55), a remote, modular waste                  license application for the proposed
sorting and repackaging system for the                geologic repository in Yucca Mountain,
DOE Savannah River Site. The completion               Nevada.     Located at the INEEL, the


                                               2-20
                                                        Chapter 2: Environmental Compliance Summary


program collaborates with other DOE                     Packaging and Transportation
laboratories to develop and deploy                      • Completed draft design requirements for
technologies that address DOE SNF                          the DOE SNF standardized canister;
management needs.         By coordinating
common needs for research, technology                   •   Performed       fracture     mechanics
development, and testing programs, the                      evaluation studies of      standardized
NSNFP is achieving cost efficiencies and                    canister drop events;
eliminating gaps and redundant activities.              •   Completed transportation cask system
    The NSNFP is divided into technical                     concept development; and
elements that address repository analysis,              •   Completed draft transportation cask
materials analysis, and packaging and                       system       design and     licensing
transportation.          Major      2000                    specification.
accomplishments are identified below as
part of these elements.                                 National Transportation Program

Repository Analysis                                         The National Transportation Program
                                                        (NTP) serves as the corporate center of
• Included DOE SNF in the repository’s
                                                        packaging and transportation expertise
   Total System Performance Assessment-                 within the DOE Office of Environmental
   Site Recommendation;                                 Management. It supports infrastructure and
•   Significantly     reduced       repository          coordinates transportation activities for all
    qualification requirements for DOE SNF;             nonclassified shipments of hazardous
                                                        materials, including radioactive and mixed
•   Completed intact and degraded mode
                                                        wastes and other commodities such as coal,
    criticality analysis and geochemical
                                                        other fuels, maintenance materials, and
    analysis for several DOE fuels;
                                                        supplies.
•   Initiated external criticality source term
                                                            The NTP is responsible for ensuring the
    of DOE SNF; and
                                                        availability of safe, secure, and economical
•   Performed preliminary DOE SNF design                transport services; consistency in regulatory
    basis events analysis showing that DOE              implementation; and coordinated outreach
    SNF will not pose unacceptable                      for DOE. A corporate team, comprised of
    radiological hazards in the repository.             personnel from the DOE-Headquarters,
                                                        DOE-ID, and DOE-Albuquerque offices,
Materials Analysis
                                                        manages the NTP. NTP Idaho is uniquely
• Defined the need and feasibility of                   responsible for transportation planning and
   advanced neutron absorbers for the                   integration activities in support of the DOE
   repository;                                          Office of Environmental Management
•   Began development         of   advanced             disposition programs.
    neutron absorbers;                                  Nuclear Reactor Technology Lead
•   Identified a potential issue with fission           Laboratories
    product attack;                                         The Secretary of Energy designated the
•   Initiated canister       remote      weld           INEEL and Argonne National Laboratory as
    development;                                        lead laboratories for nuclear reactor
                                                        technology for the DOE’s Office of Nuclear
•   Performed release rate testing showing              Energy, Science, and Technology in 1999.
    that DOE mixed oxide SNF reactions                  Both Argonne and INEEL were pioneers in
    are similar to commercial; and                      the development of safe commercial nuclear
•   Continued development of the Multi                  power. Argonne’s EBR-I located at the
    Detector        Analysis     System                 INEEL produced the first usable quantities
    nondestructive assay system.                        of nuclear energy in 1951. In 1955, Arco,


                                                 2-21
2000 Annual Site Environmental Report


Idaho, was the first city in the world lighted          that are used by 270 animal species and
by nuclear power, using electricity                     400 plant species and compose one of the
generated by INEEL’s Boiling Water                      last    undisturbed     sagebrush      steppe
Reactor Experiment-III reactor. A total of 52           ecosystems in the United States. It was
nuclear reactors have been designed, built,             part of a complexwide effort by DOE to
and operated at the INEEL over the last 50              identify,     protect,    and       conserve
years. The lead laboratories are chartered              environmentally significant parcels of land in
to:                                                     partnership with federal and state agencies.
                                                        The agreement charters the Bureau of Land
•   Maintain world-class staff and key
                                                        Management to develop a management
    facilities to pursue advanced nuclear
                                                        plan that will provide management direction
    reactor technology;
                                                        to DOE for continuance of this unique
•   Maintain a living knowledge base;                   habitat for scientific study and future
•   Evaluate and integrate the results of               generations’ benefit.
    research and development and propose
                                                            2.7 ADDITIONAL ENVIRONMENTAL
    new research;
                                                                        PROGRAMS
•   Stay    abreast    of   developments
    associated with nuclear energy-related              Public Involvement Activities
    research; and
                                                            To foster public understanding of
•   Organize national and international                 environmental issues involving the INEEL,
    forums to address key issues.                       concerted communication and education
                                                        efforts are made by DOE-ID and its
    The lead laboratories were chosen for
                                                        contractors. A wide array of tours, speaking
their complementary expertise and facilities.
                                                        engagements,        newspaper         inserts,
The INEEL has extensive expertise in light
                                                        newsletters, displays, and opportunities to
water and gas-cooled nuclear systems,
                                                        request INEEL information are made
design, development, and testing. The
                                                        available to interested persons.        News
INEEL serves needs for nuclear regulatory
                                                        releases and other contacts with journalists
and safety technical support, probabilistic
                                                        spread INEEL messages to much wider
risk analysis, nuclear engineering and
                                                        audiences. Through a toll-free telephone
design, nuclear fuels development and
                                                        number (800-708-2680), anyone can call
testing, and radiation measurements.
                                                        the INEEL to ask questions and request
Argonne has extensive expertise in liquid
                                                        copies of documents. Many documents can
metal-cooled reactors and fuel-cycle
                                                        be accessed on the Internet                 at
analysis. Argonne serves needs for safety
                                                        http://www.inel.gov/ under “About us.”
analysis, nuclear engineering and design,
                                                        INEEL public involvement activities during
fuels and fuel-cycle development, and
                                                        2000 included:
nonproliferation.
                                                        •   Publishing four INEEL Reporters;
Sagebrush Steppe Ecosystem
Reserve                                                 •   Making 205 presentations to various
                                                            groups;
   In 1999, DOE signed a memorandum of
agreement with the Bureau of Land                       •   Hosting 176 tours with a combined
Management, the U.S. Fish and Wildlife                      attendance of 2,365 people; and
Service, and the Idaho Fish and Game
                                                        •   Holding several public meetings on
Department to establish the INEEL
                                                            various topics.
Sagebrush Steppe Ecosystem Reserve.
The Reserve includes approximately                      American Indian Programs
30,000 hectares (74,000 acres) of high-                    DOE-ID      is currently focusing on
desert land within the INEEL boundaries                 expanding       and   strengthening  the


                                                 2-22
                                                       Chapter 2: Environmental Compliance Summary


government-to-government relationship with             network is mostly in place and is being
the Shoshone-Bannock Tribes of Fort Hall,              implemented by the U.S. Geological Survey
Idaho. The Tribes are close neighbors of               (USGS) as part of its ongoing program.
the INEEL and are potentially affected by              This program has been conducted since
INEEL operations. They have a vested                   1949. The development of area-specific
interest in the INEEL, as they have                    monitoring networks was initiated in 1993
inhabited     the   Snake     River     Plain          and networks have been completed at the
continuously for the past 4,500 years.                 Auxiliary Reactor Area, Special Training
DOE-ID has developed an Agreement-in-                  Facility, Power Burst Facility, and INTEC.
Principle with the Tribes that addresses               Area-specific monitoring networks are being
DOE-Indian policy and Shoshone-Bannock                 installed in accordance with the INEEL
Tribal objectives.     DOE-ID also funds               Groundwater           Monitoring       Plan
programs      and    projects  through      a          implementation schedule. Unit- and facility-
cooperative agreement, sponsored by the                specific monitoring networks were designed
DOE-Headquarters Office of Environmental               to provide leak detection. These wells are
Management, intended to enhance Tribal                 designed, installed, and monitored       as
awareness, capabilities, and participation in          needed.
INEEL activities.      The core program
                                                           The INEEL CERCLA RODs for WAG 2
addresses environmental management
                                                       (TAN), WAG 3 (INTEC), WAG 4 (CFA), and
activities including NEPA, transportation,
                                                       WAG 7 (RWMC) all contain groundwater
environmental monitoring and training,
                                                       monitoring requirements to monitor known
cultural resources management, and
                                                       plumes and the long-term performance of
emergency response and management.
                                                       remedial      actions.     The     CERCLA
                                                       groundwater monitoring requirements are
 2.8 OTHER MAJOR ENVIRONMENTAL
                                                       being integrated with the Groundwater
        ISSUES AND ACTIVITIES
                                                       Monitoring Program and the Compliance
Groundwater      Monitoring    Program                 Monitoring Program so that access to
Activities                                             specific wells is coordinated and data from
                                                       all sources can be used to analyze
    The INEEL Groundwater Monitoring                   groundwater      flow    and    contaminant
Plan established a programmatic framework              transport.
for ensuring compliance with all state,
federal, and DOE groundwater-related                       In 2000, compliance groundwater
standards. In accordance with DOE Order                monitoring was conducted at TAN and
5400.1, the plan documents local and                   INTEC as required by the Wastewater Land
regional hydrologic regimes, known and                 Application    Permit.       Observational
potential    sources     of     groundwater            groundwater monitoring was conducted by
contamination at the INEEL, and the                    the USGS in accordance with its
monitoring    networks      and    sampling            Interagency Agreement with DOE-ID (see
programs necessary to evaluate the effects             Chapter 5), and the Environmental
of the INEEL's activities on the local and             Restoration       Program      conducted
regional groundwater resources.                        groundwater         monitoring        and
                                                       characterization in accordance with the
    The INEEL Groundwater Monitoring                   INEEL FFA/CO.
Program was designed using a three-tiered
approach that integrates regional, area-               Health Studies
specific, and facility-specific/unit-specific              In August 1996, DOE and the
monitoring networks. These networks are                Department of Health and Human Services
being installed and groundwater monitoring             revised a Memorandum of Understanding
schedules are being implemented using a                under which agencies of the Department of
phased approach. The regional monitoring               Health and Human Services conduct and


                                                2-23
2000 Annual Site Environmental Report


manage epidemiological studies at DOE                  and educational workshops. This is being
facilities. The studies, including historical          conducted by PACE in conjunction with
dose       reconstruction    and     worker            Queens College of New York.
epidemiology, are financially supported by
                                                       INEEL Health Effects Subcommittee
DOE and conducted by the Centers for
Disease Control and Prevention (CDC), the                  The Department of Health and Human
Agency for Toxic Substances and Disease                Services established a public advisory
Registry (ATSDR), and the National Institute           group,     the    INEEL        Health Effects
of Occupational Safety and Health (NIOSH).             Subcommittee, to provide recommendations
The INEEL also conducts its own studies                to CDC and ATSDR regarding INEEL health
related to worker health. These studies are            studies. The Subcommittee is composed of
discussed below.                                       Idaho citizens and meets four times a year,
                                                       usually in different cities in Idaho.
INEEL Medical Surveillance
                                                       INEEL Dose Reconstruction Study
    The INEEL has a medical surveillance
program to monitor the health of current                   The CDC is conducting the INEEL Dose
workers. The program is based on routinely             Reconstruction Project. Phase II began in
collected health data, such as recordable              1996 with the start of a task to determine
injuries and illnesses specified by the                the feasibility of estimating exposures to the
Occupational     Safety    and     Health              offsite public from toxic chemicals released
Administration.   The program will help                from the INEEL. A final report was issued in
identify emerging health issues at the                 1999 concluding that none of the chemical
INEEL.                                                 releases from past INEEL operations were
                                                       of sufficient quantities to have caused
    A medical surveillance program for                 health effects to the offsite public and,
former workers at the INEEL was initiated in           therefore, did not justify inclusion in a dose
1997. The program, required by Section                 reconstruction.        A similar task for
3162 of Public Law 102-484, will evaluate              radionuclides began near the end of 1997
the long-range health conditions of former             and a draft report was issued in 2000. More
employees who may have been subjected                  information can be found at the INEEL Dose
to significant health risks from exposure to           Reconstruction              website         at
hazardous substances as a result of their              http://www.cdc.gov/nceh/radiation/brochure/
employment at the INEEL. A Phase I pilot               profile_ineel.htm.
project was completed in October 1998 by a
group of investigators consisting of the               Epidemiological Study of Workers at the
Paper, Allied-Industrial, Chemical, and                INEEL
Energy      Workers     International Union                NIOSH is conducting several studies of
(PACE); Mt. Sinai School of Medicine; the              INEEL        workers.          The     INEEL
University of Massachusetts at Lowell; and             Epidemiological Study of Workers will
Alice Hamilton College. The pilot project              evaluate patterns of mortality in all workers
resulted in findings that former INEEL                 at the INEEL since 1949 by using an all-
workers have had significant exposure to               cause cohort mortality to evaluate the
pulmonary toxins, carcinogens, renal toxins,           feasibility of a prospective cancer incidence
neurotoxins, hepatotoxins, and noise. The              study among INEEL employees. Exposures
study also concluded that epidemiological              of interest are external ionizing radiation
studies at the INEEL are lacking, workers              and a variety of chemicals. The first phase
are concerned about previous exposures,                of the study, analysis of standardized
and workers are interested in medical                  mortality ratios, is planned for completion by
screening and education programs. The                  2001.       Under a NIOSH cooperative
findings supported initiation of Phase II in           agreement, the INEEL was part of a
1999, a targeted medical surveillance                  complexwide epidemiological evaluation of
program that included medical examinations             childhood leukemia and paternal exposure


                                                2-24
                                                         Chapter 2: Environmental Compliance Summary


to ionizing radiation. The results indicated             independent oversight and monitoring
no correlation between childhood leukemia                established under the first agreement
and paternal exposure to ionizing radiation.             creating the State INEEL Oversight
                                                         Program (INEEL Oversight Program). The
CERCLA Public Health Assessment
                                                         main objectives as established under the
    ATSDR is conducting a public health                  third 5-year agreement are to:
assessment of the INEEL as required by
CERCLA for all sites on the National                     •   Assess the potential impacts of present
Priorities List. The focus of the public health              and future DOE activities in Idaho;
assessment is to provide information that                •   Assure citizens of Idaho that all present
will further the goal of preventing and                      and future DOE activities in Idaho are
mitigating      exposures     to    hazardous                protective of the health and safety of
substances released to the environment.                      Idahoans and the environment; and
The majority of the public health
assessment is expected to be completed in                •   Communicate the findings to the citizens
2001.                                                        of Idaho in a manner that provides them
                                                             the opportunity to evaluate potential
Environmental Occurrences                                    impacts of present and future DOE
    Several small spills occurred at the                     activities in Idaho.
INEEL during 2000 that were not reportable                   Oversight Program activities produced
to external agencies under environmental                 many accomplishments in 2000, due in
regulations. Six releases were determined                large part to a well-coordinated working
to be reportable to external agencies.                   relationship with DOE, INEEL contractors,
Release notifications were conducted in                  the Shoshone-Bannock Tribes, USGS,
accordance with DOE, EPA, and state of                   NOAA, and Idaho State University.
Idaho requirements. At INTEC, oxides of
nitrogen released from the calciner                      Monitoring and Surveillance Committee
exceeded air permit limits due to a                          The INEEL Monitoring and Surveillance
temperature increase and were, therefore,                Committee (MSC) was formed in March
reportable. There was also a release of                  1997 and holds monthly meetings to
more than 95 L (25 gal) of diesel fuel to soil           coordinate activities between groups
at INTEC.        CFA had two reportable                  involved in INEEL-related onsite and offsite
releases: a petroleum release of less than               environmental monitoring. This standing
19 L (5 gal) to soil that could not be cleaned           committee brings together representatives
up within 24 hours of discovery and an                   of DOE (Idaho, Chicago, and Naval
opacity exceedance for the CFA-609 boiler.               Reactors); INEEL contractors; Shoshone-
A release of less than 95 L (25 gal) of                  Bannock Tribes; Idaho DEQ; Oversight
petroleum products to the soil at Fire Station           Program; NOAA; and USGS. The MSC has
#2 was reported because it could not be                  served as a valuable forum to review
cleaned up within 24 hours of discovery. At              monitoring,    analytical,   and    quality
WROC, exceedance of the CERCLA                           assurance methodologies; to coordinate
reportable quantity for friable asbestos                 efforts; and to avoid unnecessary
triggered external agency notifications.                 duplication.
Environmental Oversight and Monitoring                   Environmental Surveillance Program
Agreement                                                   The       Environmental    Surveillance
    The Environmental Oversight and                      Program verifies and supplements existing
Monitoring Agreement (EOMA) between                      surveillance programs operated by INEEL
DOE-ID, DOE-Pittsburgh Naval Reactors                    contractors. The program's approach is
Office, Idaho Branch Office, and the state of            designed      to    provide   independent
Idaho maintains the State's program of                   assessments of potential contaminants



                                                  2-25
2000 Annual Site Environmental Report


resulting from DOE activities at the Site. It          Citizens Advisory Board
monitors multiple environmental media that
                                                           The INEEL Citizens Advisory Board,
have been or potentially could be
                                                       formerly called the Site Specific Advisory
contaminated by INEEL activities, including
                                                       Board, was formed in March 1994. Its
air, soil, milk, surface water, and
                                                       charter      is   to     provide   input    and
groundwater. External gamma radiation is
                                                       recommendations            on    environmental
also monitored under this program. Results
                                                       management’s strategic decisions that
are reported in the annual INEEL Oversight
                                                       impact future use, risk management,
Program       Environmental     Surveillance
                                                       economic        development,     and     budget
Report.
                                                       prioritization activities.
Emergency Response and Preparedness
                                                            The   board     has    produced
Program
                                                       78 recommendations to date. In 2000,
    The      EOMA    requires   emergency              14 recommendations were made on the
preparedness      assistance     to     local          following:
authorities.     DOE has assisted the
Oversight Program in establishing a                    •   Rehabilitation of Areas Affected by
Statewide Interagency Planning Group.                      Wildfire;
The group provides a process for                       •   Long-Term Stewardship;
coordinating    emergency     preparedness
issues and concerns among the various                  •   Operations of the Waste Experimental
State agencies as well as increased                        Reduction Facility Incinerator;
communication among the organizations. A               •   Draft   Programmatic     Environmental
five-phase radiological emergency response                 Impact Statement for Accomplishing
plan and emergency response training has                   Expanded Civilian Nuclear Energy
been cooperatively established with the                    Research and Development and Isotope
Oversight Program to assist the local                      Production Missions to the United
governments to meet local emergency                        States, including the Role of the Fast
response needs. The community monitoring                   Flux Test Facility;
stations have helped enhance the
monitoring parameters and locations of                 •   Environmental Impact Statement for the
meteorological conditions for use in                       Proposed Relocation of the Los Alamos
emergency planning as well as emergency                    National Laboratory Technical Area 18
response. This information is available to                 Missions;
the state of Idaho as well as the local                •   Idaho High-Level Waste and Facilities
emergency response personnel for use in                    Disposition Draft Environmental Impact
actual emergencies and for use in drills and               Statement;
exercises.
                                                       •   The Idaho National Engineering and
Impact Assessment Program                                  Environmental Laboratory Institutional
    The Impact Assessment Program                          Plan;
produces scientific validation through                 •   The Future of the Waste Experimental
independent risk assessment of current and                 Reduction Facility at the Idaho National
future operations specific to Idaho. A                     Engineering      and       Environmental
collaborative      effort improves      and                Laboratory;
scientifically validates DOE’S processes.
The activity allows the State and DOE to               •   Accessibility of Contractor Resources to
more effectively and efficiently plan future               Support     Citizen    Advisory   Board
needs in surveillance and emergency                        Deliberations;
response.




                                                2-26
                                                            Chapter 2: Environmental Compliance Summary


•     Evaluation of Ecological Health at the               •     Draft Environmental Impact Statement
      Idaho    National  Engineering     and                     for a Geologic Repository for Spent
      Environmental Laboratory;                                  Nuclear Fuel and High-Level Waste,
                                                                 Nye County, Nevada.
•     Stakeholder Involvement in Long-Term
      Stewardship Planning;
                                                                            2.9 PERMITS
•     Draft Hazardous and Polychlorinated
      Biphenyl Waste Facility Partial-Permit                   Table 2-1 summarizes permits applied
      for the Advanced Mixed Waste                         for, granted or amended and active at the
      Treatment Facility; and                              INEEL through year-end 2000.

Table 2-1. Permit summary for calendar year 2000 for the INEEL.
                                                                            Granted
      Media/Permit Type           Issuing Agency               Active       and/or         Pending
                                                                           Amended
      a
Air
Permit to Construct        State of Idaho                       10             6              0
NESHAPs (subpart H)b       EPA Region 10                         1                            0
Operating Permit           State of Idaho                       0                             1
Groundwater
Injection Well             State of Idaho                        8                             0
Well Construction          State of Idaho                        1                             0

Surface Water

Wastewater Land            State of Idaho                        4                             3
Application Permit
404 Permit                 Corps of Engineers                   1                             0
Industrial Waste           City of Idaho Falls                  15                            0
Acceptance
RCRA
Part A                     State of Idaho                        7                            0
Part Bc                    State of Idaho                        7c                           5c
a. Air permits do not include permits for the Naval Reactors Facility.
b. NESHAPs = National Emissions Standards for Hazardous Air Pollutants (40 CFR 61, Subpart H, National
   Emissions Standards for Emissions of Radionuclides Other Than Radon from Department of Energy
   Facilities).
c. The Part B permit for the INEEL is a single permit comprised of several volumes.




                                                    2-27
2000 Annual Site Environmental Report




                                        2-28

				
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