November 15, 1994




The Honorable Thomas P. Grumbly
Assistant Secretary for Environmental Management
Department of Energy
Washington, DC  20585

Dear Mr. Grumbly:

Enclosed for your information and use is a report issued by our staff
concerning the management of low level radioactive waste at the Idaho National
Engineering Laboratory.

Mr. Wallace Kornack of the Defense Nuclear Facilities Safety Board Staff will
be available to provide any additional information you may require.

                                                    Sincerely,




                                                    John T. Conway
                                                    Chairman

c:     The Honorable Tara O'Toole, EH-1
       Mr. John Wilcynski,  ID Operations Office
       Ms. Jill Lytle, EM-30
       Mr. Mark Whitaker, EH-6

Enclosure


























DEFENSE NUCLEAR FACILITIES SAFETY BOARD


September 13, 1994            


MEMORANDUM FOR:       G. W. Cunningham, Technical Director

COPIES:               Board Members

FROM:                 Steven Stokes

SUBJECT:              Trip Report - Review of Transuranic and Low-Level Waste
                      Management at the Idaho National Engineering Laboratory,
                      August 1-4, 1994

1.   Purpose:  This report documents a visit by the Defense Nuclear Facilities
     Safety Board (DNFSB) Staff (Dominic Napolitano, Mark Sautman, and Steven
     Stokes) to the Idaho National Engineering Laboratory (INEL) on August 1-4,
     1994, to review management of transuranic and low-level waste.

2.   Summary:  Transuranic (TRU) waste and low-level waste (LLW) practices at the
     Radioactive Waste Management Complex (RWMC) were reviewed to determine
     potential safety issues associated with the retrieval of TRU waste from
     above ground earthen covered storage, the Pit 9 remediation demonstration
     project, and existing low-level waste practices.

     The condition of waste packages in Pit 9 is not expected to be good due to
     the emplacement practices used in the late 1960's, and the length of time
     that the packages have been in the ground.  Therefore, significant levels
     of environmental contamination are believed to exist.  Recovery operations
     will be technically challenging and have the potential to be dose intensive
     if the proper design, training, and work planning activities are not
     performed adequately.  Department of Energy-Idaho (DOE-ID) believes that the
     completion and subsequent review of the safety analysis report and
     operational readiness activities will establish the DOE's ability to ensure
     this facility can be safely remediated.

     The draft performance assessment (PA) completed by Department of Energy-
     Idaho (DOE-ID) for the RWMC demonstrates compliance with performance
     objectives contained in DOE Order 5820.2A, Radioactive Waste Management. 
     However, the sensitivity analysis performed in the PA identifies the
     potential for exceeding the performance objectives.  Since this sensitivity
     analysis does not account for radionuclides emplaced before 1984, the dose
     estimates may even be less conservative than those reported in the draft PA.

     The cessation of operations at the Waste Experimental Reduction Facility
     (WERF), while allowing for continued waste generation, has resulted in large
     backlogs of LLW awaiting treatment.  Significant amounts of waste are
     currently stored outdoors with minimal protection from the environment.  The
     DNFSB Staff believes that initiation of properly conducted compaction and
     size reduction operations could considerably reduce the potential for
     environmental contamination. 

3.   Background:  INEL's waste management activities are focused at the RWMC. 
     RWMC operations, primarily land burial of radioactive wastes, were initiated
     in 1952 and continue to the present day.  Current RWMC activities are
     focused on: (1) the continued storage and retrieval of TRU wastes; (2)
     preparation of TRU waste for permanent disposal at the Waste Isolation Pilot
     Plant (WIPP); (3) treatment and disposal of LLW and mixed-LLW; and (4)
     resolution of disposal issues associated with greater than class-C wastes
     and other wastes not suitable for shallow land burial or disposal at WIPP.


4.   Discussion/Observations:  

     a.    Transuranic Waste (TRU) Management:  

           TRU program scope.  The scope of the TRU waste program at INEL,
           relative to other DOE Sites, is enormous.  The current estimate of the
           contact-handled TRU (CH-TRU) waste inventory stored at all DOE sites is
           103,940 m3 (1993 estimate).  Of this total, 61.8 percent is stored at
           INEL (64,235 m3).  The majority of the TRU wastes are mixed wastes (95
           percent) and, therefore, require management under the Resource
           Conservation and Recovery Act (RCRA) as well as DOE Order 5820.2A,
           Radioactive Waste Management.

           An additional category of LLW, alpha low-level waste (-LLW), which
           contains TRU radionuclide concentrations between 10 nCi/gram and 100
           nCi/gram of waste matrix, exists as a result of restrictions placed on
           shallow land disposal of TRU radionuclides.  EG&G personnel stated that
           these restrictions are the result of an environmental pathways analysis
           which was done to assess the RWMC's ability to meet performance
           objectives contained in DOE Order 5820.2A.  As a result, -LLW must be
           stored until an acceptable disposal option is developed.  Since -LLW
           is estimated to represent 42 percent of the total stored TRU inventory,
           the impact of its extended storage is not trivial.  EG&G personnel
           stated that this issue cannot be resolved until DOE-Headquarters makes
           a decision on its disposition.

           1.   Retrieval activities:  The retrieval enclosure over pads 1 and 2
                is currently under construction and is scheduled for completion in
                December 1996.  Two new RCRA compliant storage modules have been
                completed with another five  scheduled for completion in August
                1995.  The Safety Analysis Report (SAR) for the storage modules has
                been completed and approved by DOE.  The current authorization
                basis for the storage modules, as a result of  this analysis,
                allows unvented drums to be placed in the new modules.  However,
                the DNFSB Staff was told that INEL plans to vent all drums prior
                to storage in these facilities.  Operation of the storage modules
                is awaiting completion of the operational readiness review.

                Current drum venting procedures require drum removal from the
                retrieval trench and transportation to the drum venting facility. 
                Retrieval equipment, modified with protective blast shielding, is
                used to handle the unvented drums, and precautions are also taken
                to ensure that personnel are not allowed near operations involving
                unvented drums.  INEL personnel have retrieved unvented drums from
                the existing storage configurations safely on  three occasions.
                Additionally, EG&G has evaluated the safety of vent clips,
                permeable gaskets, and carbon filters.  With the exception that
                some carbon filter corrosion has been noted, their results indicate
                all three venting methods are adequate for safe removal of vented
                drums.

           2.   Pit 9 Remediation:  Pit 9 was used to store wastes from November
                1967, to June 1969.  Pit 9 wastes are primarily classified as TRU
                with the primary isotope being Pu-239 (27 Kg of Pu-239 is estimated
                to be in the pit).  The primary waste form, sludge from Rocky Flats
                processing activities, is contained in 55 gallon drums, however,
                significant quantities of processing equipment and empty
                contaminated drums were also disposed (there were over 6000 drums
                and boxes disposed of in Pit 9).

                This project is being managed by the environmental restoration
                program as part of compliance with the Comprehensive Environmental
                Response, Compensation, and Liability Act (CERCLA) as a
                demonstration project.  The current conceptual design consists of
                waste retrieval within a double contained structure built over the
                pit.  Wastes requiring treatment would be removed using remotely
                operated equipment and placed in a processing unit.  The removed
                contaminants would be treated using physical separation, chemical
                extraction, and stabilization processes.  Wastes selected for
                treatment will be >10 nCi/g TRU or exceed RCRA delisting levels as
                specified in the record of decision for this project.  Wastes that
                are <10 nCi/g TRU and do not exceed RCRA delisting levels will be
                returned to Pit 9 for disposal as LLW.  The subcontractor will be
                required to meet the existing waste acceptance criteria for the
                disposal of LLW. 

                The condition of waste containers in Pit 9 is not expected to be
                good.  None of the drums were vented.  The disposal practices used,
                dumping drums off the back of trucks into the pit, increases the
                likelihood of breached drums.  Current estimates are that ~70% of
                all drums and 100 percent of wooden boxes no longer provide waste
                containment.  Pressurization of the intact drums is also a
                potential issue.  The current design specifications require the
                subcontractor to complete a safety analysis report and conduct an
                operational readiness review in compliance with existing DOE Orders
                prior to the commencement of retrieval activities.

     b.    Low-Level Waste (LLW) Management:

           1.   INEL uses shallow land burial as its primary means of LLW disposal: 
                Greater confinement disposal vaults are used for Naval Reactor
                waste.  LLW is stored in plywood boxes and stacked in a burial pit. 
                Natural soil is used as backfill to reduce void space and a cover
                is placed over the waste.  INEL does not segregate waste in a
                manner similar to commercial facilities as required by 10 C.F.R.
                Part 61.  Inventory limits, with the exception of LLW discussed
                above, have not been established for the RWMC, and the current pit
                design does not employ a drainage system.

                Existing commercial site suitability criteria could not be met at
                the RWMC due to flooding which has occurred from snow melt.  As a
                result of this flooding, a dike system has been constructed.  No
                flooding has occurred at the RWMC since its construction. 

           2.   Waste Experimental Reduction Facility:  Waste treatment in this
                facility consists of incineration, size reduction using plasma arc
                torch cutting, and compaction.  Each of these operations is
                independent of the other.  All WERF operations were suspended in
                1991 due to conduct of operations, configuration control, and
                safety documentation problems.  Since that time, these problems
                have been addressed and plant modifications have been completed to
                provide RCRA complaint storage and new size reduction facilities. 
                A recent Operational Readiness Review was completed by DOE, and the
                contractor is currently correcting prestart findings.  While
                current plans are to initiate size reduction and compaction
                operations in the fall of 1994, no date has been set for initiation
                of incinerator operations.  Size reduction and compaction would
                have a favorable impact on reducing the large backlog of waste that
                has accumulated since cessation of WERF operations.  Since a large
                majority of these are stored outdoors with minimal protection from
                the environment, the treatment and disposal of these wastes would
                eliminate the potential for environmental contamination.

           3.   Performance Assessment (PA):  INEL is developing a PA in compliance
                with DOE Order 5820.2A.  Currently, a draft PA has been prepared,
                however, it has only been preliminarily reviewed by DOE's Peer
                Review Panel to determine its technical adequacy.  DNFSB Staff
                review of the draft PA indicates that performance objectives appear
                to be met.  However, the 25 mrem/yr protection of the public from
                all pathways objective is only marginally met due to a predicted
                dose of 17 mrem/yr in the period after institutional control. 
                Review of the sensitivity analysis in the draft PA revealed a range
                of all pathways doses after institutional control of  9.5 to 29
                mrem/yr.  Since this sensitivity analysis does not account for
                radionuclides emplaced before 1984, the dose estimates may be less
                conservative than reported in the draft PA.  Additionally, by
                dividing the source term arbitrarily by time of emplacement (pre-
                1984 or post-1983), INEL cannot show that the design of existing
                or planned disposal facilities is sufficient to keep dose rates to
                the public below performance objectives outlined in DOE Order
                5820.2A.

                DOE-ID has taken a unique perspective on determining the impact
                from the totality of  waste operations at the RWMC.  Since INEL has
                been placed on the National Priority List and is subject to CERCLA,
                the remedial investigation/field study process is used to determine
                the safety and health significance of waste disposed at the RWMC. 
                A Remedial Investigation/Field Study (RI/FS) for Pad A, related to
                organic contamination in the vadose zone, has been completed and
                an RI/FS for RWMC's Pits and Trenches is scheduled to begin within
                the next 8-9 months (this study has an approximate duration of 40
                months).  The scope of the Pits and Trenches RI/FS includes burial
                grounds that will have been operated between 1952 and 1997 (this
                will represent the entire buried source term at INEL when the
                record of decision is issued).  This approach is unique in that the
                study will be used to make remediation and closure decisions
                related to both past and existing low-level waste disposal
                facilities.    A performance assessment is also being completed. 
                This study will assess waste disposed from 1984 to 2020 and measure
                compliance with performance objectives contained in DOE Order
                5820.2A and assist in active pit closure decisions.  Discussions
                with DOE-ID personnel indicate that if  the results of the two
                studies conflict , i.e., the risk assessment portion of the RI/FS
                finds that the consequences of operating existing facilities
                exceeds public health and safety criteria established in CERCLA
                while the PA indicates that performance objectives are being met,
                the continued operation of existing facilities will be reassessed. 
                 If this approach is fully implemented, the technical staff sees
                this as a  positive step towards a systematic approach to
                evaluating the totality of low-level waste disposal operations.  
  

5.   Future Staff Actions:  Staff activities will focus on the safety aspects of
     the Pit 9 remediation project, retrieval of TRU wastes, restart of the WERF,
     a more detailed review of safety analysis reports related to these
     activities, and a more detailed review of the draft performance assessment
     for the RWMC.