ML24172A118
| ML24172A118 | |
| Person / Time | |
|---|---|
| Site: | PROJ0735 |
| Issue date: | 07/29/2024 |
| From: | NRC/NMSS/DDUWP/LLWPB |
| To: | Idaho National Lab |
| Shared Package | |
| ML24172A110 | List: |
| References | |
| Download: ML24172A118 (1) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION APRIL 30, 2024, ONSITE OBSERVATION VISIT REPORT FOR THE IDAHO NATIONAL LABORATORY IDAHO NUCLEAR TECHNOLOGY AND ENGINEERING CENTER TANK FARM FACILITY
EXECUTIVE
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) staff conducted its 10th onsite observation visit (OOV) to the Idaho Nuclear Technology and Engineering Center (INTEC) Tank Farm Facility (TFF) at the Idaho National Laboratory (INL) on April 30, 2022. This is the first INTEC TFF OOV in Calendar Year (CY) 2024. On every OOV to INL, the NRC is focused on assessing the U.S. Department of Energy (DOE) compliance with four performance objectives in Title 10 of the Code of Federal Regulations (CFR) Part 61, Subpart C: (1) protection of the general population from releases of radioactivity (§61.41), (2) protection of individuals from inadvertent intrusion (§61.42), (3) protection of individuals during operations (§61.43), and (4) stability of the disposal site after closure (§61.44). If the NRC concludes with reasonable assurance that the DOE complies with §61.41, §61.42, §61.43, and §61.44, then the NRC will also conclude with reasonable assurance that the DOE complies with §61.40.
For this OOV, the NRC focused on the key monitoring areas in the INTEC TFF Monitoring Plan, Rev. 0 (dated April 2007) [available via the NRC Agencywide Documents Access and Management System (ADAMS) at Accession No. ML070650222]. The NRC performs monitoring activities in coordination with the state of Idaho. Therefore, the NRC provided the Idaho Department of Environmental (IDEQ) staff the opportunity both to participate in this OOV and to receive the same information from the DOE as the NRC received from the DOE during this OOV. The NRC staff met with the IDEQ staff prior to this OOV on June 21,2022.
As described in the NRC Onsite Observation Guidance Memorandum for this OOV (dated April 14, 2024) [ADAMS Accession No. ML24100A045] and as added to during the OOV, the main activities conducted during the OOV were a tour and technical discussions. The tour focused on the INTEC facilities. The technical discussions focused on: (i) the operating status; (ii) the radiation protection program; (iii) the environmental sampling program; and (iv) the engineered surface barrier construction program. An Onsite Observation Guidance Memorandum is a plan for what the NRC expects to cover during an OOV, which may be changed based on what happens during the OOV.
2.0 NRC OOV ACTIVITIES:
On April 14, 2024, the NRC issued the Onsite Observation Guidance Memorandum [ADAMS Accession No. ML24100A045) for the April 30,2024, INTEC TFF Observation. An Onsite Observation Guidance Memorandum is a plan for what the NRC expects to cover during an OOV, which may be changed based on what happens during the OOV.
The OOV began with introductions and welcoming remarks followed by a short briefing on the agenda. This OOV was attended by representatives from the DOE (staff and contractors) and the NRC. The rest of the OOV consisted of a tour and technical discussions. The tour focused on the INTEC facilities. The technical discussions focused on: (i) the operating status; (ii) the radiation protection program; and (iii) the environmental sampling program.
Enclosure 2.1 Tour and Technical Discussion - Operating Status
2.1.1 Observation Scope:
The tour and technical discussion supported the NRC monitoring of the DOE disposal actions to assess compliance with 10 CFR 61.43. The tour and technical discussion was most relevant to the following key monitoring areas (KMAs) in the INTEC TFF Monitoring Plan, Rev.
0:
- KMA 4 - Monitoring During Operations o The NRC monitoring of the DOE activities related to the radiation protection program for more risk-significant tank closure activities (e.g., reviewing radiation records and As Low As Is Reasonably Achievable (ALARA) documentation) is important because those DOE activities help ensure that the public and the workers radiation dose limits specified in 10 CFR Part 20 (i.e.,
similar to the DOE regulations and orders) are met.
- KMA 5 - Engineered Surface Barrier/Infiltration Reduction o The NRC monitoring of the DOE activities related to design, installation, and maintenance of the engineered cover is important because those DOE activities are pertinent to the infiltration rates, which are important to the radionuclide release rates and those infiltration rates should be consistent with or lower than those assumed in the DOE performance assessment.
Observation Results:
The key points from the tour and technical discussion were:
- DOE discussed current and planned closure activities at the INTEC TFF, which have been delayed for several years due to operational issues with the Integrated Waste Treatment Unit (IWTU).
- DOE updated NRC with the current outlook for cleanup and closure of the four remaining 1,000 m3 high-level waste tanks (including one spare tank). Closure of the tanks is dependent upon continued troubleshooting and testing of the IWTU where waste retrieved from the tanks is being sent for processing and stabilization.
- DOE continues to make progress testing IWTU. At the time of the onsite observation, the IWTU was shut down to address issues with early degradation and more frequent replacement of materials in the off-gas system used to filter releases from the facility.
- DOE is testing different IWTU feed strategies and is considering options for future IWTU operation including blending residual tank heel waste with lower activity sodium bearing waste. DOE stated they plan to restart IWTU operation in CY25 and that it may take several years to process the remaining approximately 900,000 gallons (3000 m3) of waste. NRC will continue to monitor DOE disposal activities including waste retrieval operations of the four remaining tanks left to be cleaned and closed, and future grouting of the tanks to stabilize the residual heel.
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- Although outside the scope of NRCs monitoring responsibilities, DOE provided a tour of the IWTU facility and New Waste Calcine facility which is used to transfer waste from the INL INTEC TFF to the IWTU.
2.1.2 Conclusions and Follow-up Action Items:
The NRC staff will continue to monitor the DOE INTEC TFF activities related to the operating status. There were no Follow-Up Action Items that resulted from either the tour or the technical discussion.
2.2 Technical Discussion - Radiation Protection Program (RPP)
2.2.1 Observation Scope:
The technical discussion supported the NRC monitoring of the DOE disposal actions to assess compliance with 10 CFR 61.43.
2.2.2 Observation Results:
The key points from the technical discussion were:
- The DOE provided the NRC with information on INTEC TFF activities that had occurred since the previous OOV in July 2019:
o DOE indicated that since the last OOV no major activities took place that incurred significant radiation doses.
o DOE indicated that in 2023 they replaced a contaminated sump pump.
o DOE establishes an as low ALARA individual worker dose goal of 100 mrem per year (1 mSv per year) and can increase that goal to 300-500 mrem (3-5 mSv) if needed for more risk-significant jobs.
o Electronic dosimeters and thermoluminescent dosimeters are used to record worker dose. The Radiation Work Permit contains information on collective dose for each tank farm activity.
2.2.3 Conclusions and Follow-up Action Items:
The NRC staff will continue to monitor the DOE INTEC TFF activities related to the RPP. There were no Follow-Up Action Items that resulted from the technical discussion.
2.3 Technical Discussion - Environmental Monitoring Program (EMP)
2.3.1 Observation Scope:
The technical discussion supported the NRC monitoring of the DOE disposal actions to assess compliance with 10 CFR 61.43. The technical discussion was most relevant to the following KMA in the INTEC TFF Monitoring Plan, Rev. 0:
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- KMA 4 - Monitoring During Operations o The NRC monitoring of the DOE activities related to the RPP for more risk-significant tank closure activities (e.g., reviewing radiation records and ALARA documentation) is important because those DOE activities help ensure that the public and the workers radiation dose limits specified in 10 CFR Part 20 (i.e.,
similar to the DOE regulations and orders) are met.
2.3.2 Observation Results:
The key points from the technical discussion were:
- Prior to the OOV, The NRC reviewed the Fiscal Year 2022 Annual Report for Operable Unit 3-14, Tank Farm Soil and INTEC Groundwater, DOE/ID-12078, Rev. 0.
NRC asked questions about the annual report during the OOV.
- NRC also reviewed Department of Environmental Quality-INL Oversight Program 2023 quarterly reports (for the 1Q, 2Q, and 3Q of 2023); and the 2021 and 2022 Annual Reports.
- In 2023, maintenance activities conducted under the Comprehensive Environmental Response Compensation and Liabilities Act (CERCLA) Record of Decision for the INTEC TFF included repair of a secondary liner on the evaporation pond where tank farm runoff is diverted.
- Under the CERCLA program, DOE also continues to monitor the recharge control zone (20 wells) and indicated that no specific leaks were identified, although the source of seasonal increases in perched water in the east perched area of INTEC TFF near IWTU and well MW-4-2 (and other nearby wells) is still being investigated.
- Temporary asphalt will be placed over the sections of the tank farm after the final tanks are operationally closed. Repairs to existing degraded asphalt and sealant/coating are ongoing.
- The NRC review of monitoring data associated with the INTEC TFF revealed no new or significant information related to the performance of the disposal facility and most notably the hydrological system at the INL INTEC TFF.
- The similarity between the IDEQ data and DOE monitoring data provides NRC with confidence that both programs provide reasonable representations of the environment surrounding INL.
2.3.3 Conclusions and Follow-up Actions:
The NRC staff will continue to monitor DOE INTEC TFF activities related to the EMP. NRC will continue to coordinate with the IDEQ and leverage data and information collected as part of its independent oversight activities to help NRC fulfill its responsibilities under the National Defense Authorization Act (NDAA)to monitor DOE disposal activities at the INL INTEC TFF in coordination with the covered state. There were no Follow-Up Action Items that resulted from the technical discussion.
4 3.0 OVERALL CONCLUSIONS STATUS OF KMAs, OPEN ISSUES, OPEN FOLLOW-UP ACTION ITEMS, AND ISSUANCE OF NRC TECHNICAL REVIEW REPORTS:
3.1 Overall
Conclusions:
There is no change to the NRC staff overall conclusions from the 2006 TER regarding compliance of the disposal actions with the 10 CFR Part 61 performance objectives. The main key message from the OOV was that the NRC staff did not identify the need for any new KMAs. The NRC staff continues to have reasonable assurance that the Part 61 POs can be met.
3.2 Status of KMAs in INTEC TFF Monitoring Plan, Rev.0:
INTEC TFF Observation 2024 is the tenth OOV under INTEC TFF Monitoring Plan, Rev.
- 0. KMA 3 was closed in June 2014 [ADAMS Accession No. ML14149A337]. The NRC staff did not close any KMAs during this OOV. Therefore, KMA 4, KMA 5 and from INTEC TFF Monitoring Plan, Rev. 0 remain open.
4.0 PARTICIPANTS
U.S. NRC U.S. DOE & DOE Contractor
Cynthia Barr Valerie Kimbro Maurice Heath Trent Neville Duane White Tyler Buttersworth Chris McKenney Ken Brewer Louis Caponi Gregery Balsmeier William Kirby Jimmy Spells
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5.0 REFERENCES
- 1. 10 CFR Part 61, Federal Register, Licensing Requirements for Land Disposal of Radioactive Waste, Code of Federal Regulations, Office of the Federal Register, January 2001.
- 2. Idaho Department of Environmental Quality (DEQ), INL Oversight Program, Environmental Surveillance Program, Quarterly Data Report, January-March, 2023, Idaho Falls, Idaho, 2023.
- 3. Idaho DEQ, INL Oversight Program, Environmental Surveillance Program, Quarterly Data Report, April-June, 2023, Idaho Falls, Idaho, 2023.
- 4. Idaho DEQ, INL Oversight Program, Environmental Surveillance Program, Quarterly Data Report, July-September, 2023, Idaho Falls, Idaho, 2023.
- 5. Idaho DEQ, INL Oversight Program, DEQ-INL Oversight Program Annual Report 2021, Idaho Falls, Idaho, 2022.
- 6. Idaho DEQ, INL Oversight Program, DEQ-INL Oversight Program Annual Report 2022, Idaho Falls, Idaho, 2023.
- 7. U.S. DOE, DOE Idaho Operations Office, Fiscal Year 2022 Annual Report for Operable Unit 3-14, Tank Farm Soil and INTEC Groundwater, DOE/ID-12078, Rev. 0, Idaho Falls, Idaho, May 2023.
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