September 18, 2012 

Mr. Robert M. Shaw 

Project Manager, Tank Farm Closure Project 

U.S. Department of Energy, Idaho Operations Office 

MS-1222 

1955 Freemont Avenue 

Idaho Falls, ID 83415 

SUBJECT: U.S. NUCLEAR REGULATORY COMMISSION ONSITE OBSERVATION 

REPORT FOR THE IDAHO NATIONAL LABORATORY IDAHO NUCLEAR 

TECHNOLOGY AND ENGINEERING CENTER TANK FARM FACILITY 

Dear Mr. Shaw: 

The enclosed document describes the U.S. Nuclear Regulatory Commission’s (NRC’s) onsite 

observation activities on June 19, 2012, for monitoring disposal actions taken by the 

U.S. Department of Energy (DOE) at the Idaho National Laboratory (INL), Idaho Nuclear 

Technology and Engineering Center Tank Farm Facility (INTEC TFF). This onsite observation 

was conducted in accordance with the Ronald Reagan National Defense Authorization Act for 

Fiscal Year 2005 (NDAA), which requires NRC to monitor disposal actions taken by the DOE for 

the purpose of assessing compliance with the performance objectives set out in Subpart C of 

Part 61 of Title 10 of the Code of Federal Regulations. 

NRC’s onsite observation at INL supported assessment of compliance with the 10 CFR 61.43 

performance objective. The main focus was to verify DOE’s radiation protection and 

environmental monitoring programs at the INTEC TFF. Because environmental monitoring data 

also provides information to assess performance assessment models, this onsite observation 

also partially addresses the 10 CFR 61.41 performance objective. Additional visits will be 

conducted in the future to assess compliance with all of the performance objectives in 10 CFR 

Part 61, Subpart C. 

If you have any questions or need additional information regarding this report, please call me at 

301-415-7479, or call Maurice Heath, Project Manager of my staff, at 301-415-3137. 

 Sincerely, 

 /RA/ 

 Andrew Persinko, Deputy Director 

 Environmental Protection and Performance 

 Assessment Directorate 

 Division of Waste Management 

 and Environmental Protection 

 Office of Federal and State Materials 

 and Environmental Management Programs 

Enclosure: 

NRC Observation Report
Mr. Robert M. Shaw 

Project Manager, Tank Farm Closure Project 

U.S. Department of Energy, Idaho Operations Office 

MS-1222 

1955 Freemont Avenue 

Idaho Falls, ID 83415 

SUBJECT: U.S. NUCLEAR REGULATORY COMMISSION ONSITE OBSERVATION 

REPORT FOR THE IDAHO NATIONAL LABORATORY IDAHO NUCLEAR 

TECHNOLOGY AND ENGINEERING CENTER TANK FARM FACILITY 

Dear Mr. Shaw: 

The enclosed document describes the U.S. Nuclear Regulatory Commission’s (NRC’s) onsite 

observation activities on June 19, 2012, for monitoring disposal actions taken by the 

U.S. Department of Energy (DOE) at the Idaho National Laboratory (INL), Idaho Nuclear 

Technology and Engineering Center Tank Farm Facility (INTEC TFF). This onsite observation 

was conducted in accordance with the Ronald Reagan National Defense Authorization Act for 

Fiscal Year 2005 (NDAA), which requires NRC to monitor disposal actions taken by the DOE for 

the purpose of assessing compliance with the performance objectives set out in Subpart C of 

Part 61 of Title 10 of the Code of Federal Regulations. 

NRC’s onsite observation at INL supported assessment of compliance with the 10 CFR 61.43 

performance objective. The main focus was to verify DOE’s radiation protection and 

environmental monitoring programs at the INTEC TFF. Because environmental monitoring data 

also provides information to assess performance assessment models, this onsite observation 

also partially addresses the 10 CFR 61.41 performance objective. Additional visits will be 

conducted in the future to assess compliance with all of the performance objectives in 10 CFR 

Part 61, Subpart C. 

If you have any questions or need additional information regarding this report, please call me at 

301-415-7479, or call Maurice Heath, Project Manager of my staff, at 301-415-3137. 

 Sincerely, 

 Andrew Persinko, Deputy Director 

 Environmental Protection and Performance 

 Assessment Directorate 

 Division of Waste Management 

 and Environmental Protection 

 Office of Federal and State Materials 

 and Environmental Management Programs 

Enclosure: NRC Observation Report 

ML12240A037

OFC DWMEP LA DWMEP DWMEP DWMEP DWMEP 

NAME MHeath TMoon CBarr CMcKenney GSuber APersinko 

DATE 8/24/12 8/28/12 8/24/12 8/18/12 8/28/12 9/18/12 

OFFICIAL RECORD COPY
Enclosure 

IDAHO NATIONAL LABORATORY IDAHO NUCLEAR TECHNOLOGY AND ENGINEERING 

CENTER TANK FARM FACILITY

U.S. NUCLEAR REGULATORY COMMISSION ONSITE OBSERVATION REPORT 

1.0 BACKGROUND: 

The National Defense Authorization Act (NDAA) for Fiscal Year 2005 authorizes U.S. 

Department of Energy (DOE), in consultation with the U.S. Nuclear Regulatory Commission 

(NRC), to determine whether certain radioactive waste related to the reprocessing of spent 

nuclear fuel is not high-level waste, provided certain criteria are met. The NDAA also requires 

NRC to monitor DOE disposal actions to assess compliance with 10 CFR Part 61, Subpart C, 

performance objectives for low-level waste. 

On September 7, 2005, DOE submitted a draft waste determination for residual waste incidental 

to reprocessing stored in the Idaho Nuclear Technology and Engineering Center Tank Farm 

Facility (INTEC TFF) to demonstrate compliance with the NDAA criteria including demonstration 

of compliance with the performance objectives in 10 CFR Part 61, Subpart C. In its consultation 

role, the NRC staff reviewed the draft waste determination and concluded that the NDAA criteria 

could be met for residual waste stored in the INTEC TFF. NRC documented the results of its 

review in a Technical Evaluation Report (TER) issued in October 2006 (NRC, 2006). DOE 

issued a final waste determination in November 2006 taking into consideration the assumptions, 

conclusions, and recommendations documented in NRC’s TER (DOE Idaho, 2006). 

To carry out its monitoring responsibilities under the NDAA, NRC developed a monitoring plan 

for the INTEC TFF facility in April 2007 (NRC, 2007). The NRC conducted two onsite 

observations in 2007 to observe tank grouting operations (7 of 11 large tanks and 4 smaller 

tanks) at the INTEC TFF. All open items identified in the first onsite observation conducted in 

April 2007 (ML071300222) were closed in the August 2007 onsite observation (ML072570173). 

In August 2008, NRC staff participated in a third onsite observation to observe pipe grouting 

operations, radiation protection controls, and the environmental sampling program 

(ML082050071). No findings resulted from the three onsite observations. No significant tank 

farm closure activities occurred in calendar year 2009; therefore, NRC staff elected to forego an 

onsite observation. No significant closure activities occurred at the INTEC TFF in calendar year 

2010; however, given the length of time that had elapsed since the last onsite observation, the 

NRC staff decided to conduct an onsite observation visit in August 2010. The staff’s visit did not 

identify any significant issues; however the staff did have two recommendations for DOE to 

consider when performing its annual checklist to determine if the INTEC TFF Performance 

Assessment should be updated. The staff documented its results in the October 2010 

observation report (ML102770022). In July 2012 the NRC decided to conduct another onsite 

observation to obtain additional information and observe, as appropriate, disposal actions 

related to closure of the remaining 4 large tanks. During the visit, NRC staff obtained updates 

on closure activities and schedules, and collected routine information related to several 

monitoring factors listed in NRC’s monitoring plan for the INTEC TFF (ML070650222), such as 

radiation protection and environmental monitoring programs. Prior to the onsite observation on 
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June 18, NRC staff met with officials from the State of Idaho Department of Environmental 

Quality (IDEQ) to discuss the INL Oversight program and environmental monitoring at INTEC 

and the larger INL site. 

2.0 NRC ONSITE OBSERVATION ACTIVITIES: 

On June 19, 2012, NRC staff visited the INL site and listened to presentations by DOE 

regarding current and planned closure activities at the INTEC TFF. DOE provided information 

regarding delays in the schedule for closure of four large, 1000 m3

 high-level waste tanks 

(including one spare tank) related to issues with start-up of the Integrated Waste Treatment Unit 

(IWTU) that will be used to treat the sodium-bearing waste remaining in the tanks. Despite 

uncertainty in the timing of start-up of the IWTU, DOE has taken steps to prepare for bulk waste 

removal, heel retrieval, and grouting of the four tanks including design modifications, 

refurbishment and testing of existing wash equipment; fabrication and installation of steam jets 

and above-ground transfer lines; activation of wash procedures; and preparation of liquid 

transfer sheets to support cleaning operations. DOE discussed modifications that were made to 

wash and grout equipment based on lessons learned from prior campaigns. DOE also 

discussed differences between the tanks that have been cleaned and the four remaining tanks 

yet to be cleaned (e.g., differences in cooling coil supports). Spare tank, WM-190, has been 

outfitted with a wash ball and steam jet to facilitate testing and readiness once the IWTU comes 

on-line. DOE also provided a tour of INTEC facilities, including a walk-down of structures and 

tents that support tank farm closure activities. 

2.1 RADIATION PROTECTION: 

2.1.1 Observation Scope:

During the onsite observation, NRC staff participated in discussions with DOE and DOE 

contractor staff regarding completed and planned tank farm closure activities to obtain a better 

understanding of the types of activities that may lead to the greatest risks to radiation workers 

and members of the public during tank farm closure. NRC staff also obtained information 

regarding radiological controls during wash and grouting operations. NRC staff will continue to 

monitor DOE’s radiation protection program related to tank farm closure in a future onsite 

observation or through technical review of documentation such as radiation work permits, 

worker dose records, and ALARA documentation as tank farm closure activities progress. 

2.1.2 Observation Results: 

NRC staff identified no issues or follow-up actions related to DOE’s radiation protection 

program. 

2.1.3 Conclusions: 

NRC staff continues to have reasonable assurance that the performance objective in 10 CFR 

61.43 can be met. 
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2.2 ENVIRONMENTAL MONITORING: 

2.2.1 Observation Scope: 

During this onsite observation visit, NRC staff listened to presentations and participated in 

discussions with DOE and contractor staff regarding ongoing remedial actions and groundwater 

monitoring activities performed under the Comprehensive Environmental Response, 

Compensation, and Liability Act (CERCLA) program at the INTEC TFF. Prior to the onsite 

observation, NRC staff also met with officials from the Idaho Department of Environmental 

Quality (IDEQ) to discuss its oversight of the site, specifically related to its independent 

environmental surveillance program. 

NRC staff inquired about continued sampling of an INTEC TFF groundwater well north of the 

tank farm (ICPP-MON-A-230) that had elevated concentrations of Tc-99 over the past several 

years. NRC staff obtained information regarding the latest groundwater monitoring results and 

recently issued groundwater monitoring reports. NRC staff will document the results of its 

review of these documents in a separate technical review document. 

NRC staff also inquired about DOE’s performance assessment maintenance plan and annual 

check-list used to facilitate decision-making regarding the need for supplementary analyses or 

modifications to key closure documents. DOE provided NRC staff with a copy of the 

“Compliance and Monitoring Plan for Performing Grouting at the INTEC Tank Farm Facility 

Closure Project” (DOE Idaho, 2010). This plan contains a check-list in Appendix D that 

indicates that types of triggers that might warrant further evaluation. This check-list was used 

by DOE in 2010 and triggered supplementary analysis by DOE to evaluate the impact of more 

vertical (rather than lateral) flow of groundwater released from INTEC tanks to the Snake River 

Plain Aquifer. Based on the supplementary analysis, DOE concluded that the doses could be a 

factor of 2 higher than predicted by the PA (DOE Idaho, 2003). However, the doses were still 

significantly below the performance objectives in 10 CFR Part 61, Subpart C. NRC staff 

reviewed DOE’s supplementary analysis and found it to be acceptable. The results of NRC 

staff’s review of the supplementary analysis will be provided in the calendar year 2011 periodic 

compliance monitoring report to be issued later this year. 

2.2.2 Observation Results: 

NRC staff identified no issues or follow-up actions related to DOE’s environmental monitoring 

program. NRC staff continues to coordinate with the IDEQ and to rely on its oversight of INTEC 

TFF activities through its independent environmental surveillance program. NRC staff finds 

DOE’s annual check-list to be an adequate tool to ensure that new and significant information 

that may impact the conclusions in DOE’s waste determination (DOE Idaho, 2006) or supporting 

PA (DOE Idaho, 2003) is evaluated to ensure that INTEC TFF disposal actions are compliant 

with the performance objectives in 10 CFR Part 61, Subpart C. 

2.2.3 Conclusions and Follow-up Actions: 

NRC continues to have reasonable assurance that the performance objectives in 10 CFR Part 

61, Subpart C can be met. 
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3.0 PARTICIPANTS: 

NRC Observation Team 

Barr, Cynthia 

Schwartzman, Adam 

Heath, Maurice 

McKenney, Christepher 

Idaho Department of Environmental Quality 

Dietrich, Mark 

LaRue, Bruce 

Partial List of DOE Representatives 

Shaw, Robert (Mark) 

Bryant, Jeff 

Butterworth, Steve 

Davis, Robert 

Evans, Susan 

Harris, Trent 

Howard, Terry 

Hutchison, David 

Lehrer, Steve 

Long, Jeff 

McCollum, Robyn 

Rielly, Pat 

4.0 REFERENCES: 

DOE Idaho. “Basis for Section 3116 Determination for the Idaho Nuclear Technology and 

Engineering Center Tank Farm Facility.” DOE/NE-ID-11226, Revision 0. November 2006. 

DOE Idaho. “Compliance and Monitoring Plan for Performing Grouting at the INTEC Tank Farm 

Facility Closure Project.” PLN-2309, Revision 3. October 6, 2010. 

DOE Idaho. DOE/ID–10966, “Performance Assessment for the Tank Farm Facility at the Idaho 

National Engineering and Environmental Laboratory.” Rev. 1. (Errata December 2, 2003). 

Idaho Falls, Idaho: DOE Idaho. 2003. 

NRC. "U.S. Nuclear Regulatory Commission Plan for Monitoring Disposal Actions Taken by the 

U.S. Department of Energy at the Idaho National Laboratory Idaho Nuclear Technology and 

Engineering Center Tank Farm Facility in Accordance with the National Defense Authorization 

Act for Fiscal Year 2005." Washington, D.C.: NRC. 2007. ML070650222. 

NRC. "U.S. Nuclear Regulatory Commission Technical Evaluation Report for the U.S. 

Department of Energy Idaho National Laboratory Site Draft Section 3116 Waste Determination 

for Idaho Nuclear Technology and Engineering Center Tank Farm Facility." Washington, DC: 

NRC, 2006. ML052630012. 
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