June 9, 2014 

Mr. Robert M. Shaw 

Project Manager, Tank Farm Closure Project 

U.S. Department of Energy, 

Idaho Operations Office 

1955 Freemont Avenue, MS-1222 

Idaho Falls, ID 83415 

SUBJECT: U.S. NUCLEAR REGULATORY COMMISSION CLOSURE OF KEY 

MONITORING AREA 3, IN THE IDAHO NATIONAL LABORATORY IDAHO 

NUCLEAR TECHNOLOGY AND ENGINEERING CENTER TANK FARM 

FACILITY MONITORING PLAN (PROJECT NO. PROJ0735) 

Dear Mr. Shaw: 

The Ronald Reagan National Defense Authorization Act for Fiscal Year 2005 (NDAA) 

authorizes the U.S. Department of Energy (DOE) in consultation with the U.S. Nuclear 

Regulatory Commission (NRC) to determine whether certain radioactive waste related to 

reprocessing of spent nuclear fuel is not high-level waste, provided certain criteria are met. 

The NDAA also requires NRC to coordinate with the covered state (i.e., South Carolina or 

Idaho) 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 and supporting 

performance assessment 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. The NRC documented the results of its review in a technical 

evaluation report (TER). 

The NRC identified key attributes of the disposal facility, or key monitoring areas (KMAs), in its 

TER that are important to mitigating releases of radioactivity to the environment or that are 

otherwise important to DOE’s demonstration of compliance with 10 CFR Part 61, performance 

objectives. The NRC developed a plan for monitoring the INTEC TFF in 2007 focusing on the 

KMAs listed in NRC’s TER. 

Since 2007, the NRC staff has performed a number of technical review activities and onsite 

observation visits that address KMA 3, “Hydrological Uncertainties”, as detailed in the NRC 

staff’s plan for monitoring the Idaho National Laboratory. The NRC staff developed KMA 3 to 

address a number of technical uncertainties associated with the DOE’s representation of the 

hydrological system at the INTEC TFF, as it impacts the level of natural system performance 

assumed in DOE’s groundwater model. 
R. Shaw - 2 - 

In 2011, DOE prepared a supplementary analysis to address many of the NRC staff’s key 

technical issues associated with DOE’s groundwater model, including concerns regarding the 

influence of Big Lost River seepage on attenuating releases from the INTEC TFF. The 

supplemental analysis showed that while the projected doses could be a factor of 2 higher, the 

10 CFR 61.41 performance objective could still be met. 

The NRC staff has reviewed a number of hydrological studies and environmental monitoring 

reports, since it began monitoring the INTEC TFF in 2007. While review of this additional 

information has increased the NRC staff’s understanding of the hydrological system at the 

INTEC TFF, the information has not fundamentally changed the NRC staff’s understanding of 

the technical uncertainties, nor has it changed the NRC staff’s TER conclusions. Therefore, the 

NRC staff has decided to close KMA 3, “Hydrological Uncertainties”, at this time. Should 

technical issues arise in the future, the NRC staff may reopen KMA 3, or create a new 

monitoring area. The NRC staff will also continue to review environmental monitoring reports 

routinely under KMA 4 “Monitoring During Operations”, in conjunction with future onsite 

observation visits. 

In accordance with 10 CFR 2.390 of the NRC’s “Agency Rules of Practice and Procedure,” a 

copy of this letter will be available electronically for public inspection in the NRC Public 

Document Room or from the Publicly Available Records component of NRC’s Agencywide 

Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC 

Web site at http://www.nrc.gov/reading-rm/adams.html. 

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

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

 Sincerely, 

 /RA/ 

 Aby Mohseni, 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 
R. Shaw -2- 

In 2011, DOE prepared a supplementary analysis to address many of the NRC staff’s key 

technical issues associated with DOE’s groundwater model, including concerns regarding the 

influence of Big Lost River seepage on attenuating releases from the INTEC TFF. The 

supplemental analysis showed that while the projected doses could be a factor of 2 higher, the 

10 CFR 61.41 performance objective could still be met. 

The NRC staff has reviewed a number of hydrological studies and environmental monitoring 

reports, since it began monitoring the INTEC TFF in 2007. While review of this additional 

information has increased the NRC staff’s understanding of the hydrological system at the 

INTEC TFF, the information has not fundamentally changed the NRC staff’s understanding of 

the technical uncertainties, nor has it changed the NRC staff’s TER conclusions. Therefore, the 

NRC staff has decided to close KMA 3, “Hydrological Uncertainties”, at this time. Should 

technical issues arise in the future, the NRC staff may reopen KMA 3, or create a new 

monitoring area. The NRC staff will also continue to review environmental monitoring reports 

routinely under KMA 4 “Monitoring During Operations”, in conjunction with future onsite 

observation visits. 

In accordance with 10 CFR 2.390 of the NRC’s “Agency Rules of Practice and Procedure,” a 

copy of this letter will be available electronically for public inspection in the NRC Public 

Document Room or from the Publicly Available Records component of NRC’s Agencywide 

Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC 

Web site at http://www.nrc.gov/reading-rm/adams.html. 

 Sincerely, 

 /RA/ 

 Aby Mohseni, 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 

ML14149A337

OFC DWMEP LA DWMEP DWMEP DWMEP DWMEP 

NAME MHeath AWalkerSmith 

CBarr CMcKenney GSuber AMohseni 

DATE 5/30/14 5/30/14 5/30/14 6/2/14 6/2/14 6/9/14 

OFFICIAL RECORD COPY