September 24, 2014 

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 

(PROJ0735) 

Dear Mr. Shaw: 

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

observation activities on June 26, 2014, 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, 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 objectives. 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 objectives. Additional visits will be 

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

Part 61, Subpart C. 
R. Shaw 2 

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

301-415-8087, or call Mr. Maurice Heath, Project Manager of my staff, at 301-415-3137. 

 Sincerely, 

 /RA/ 

 Gregory Suber, Acting 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
R. Shaw 2 

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

301-415-8087, or call Mr. Maurice Heath, Project Manager of my staff, at 301-415-3137. 

 

 Sincerely, 

 /RA/ 

 Gregory Suber, Acting 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 

ML14265A092

OFC DWMEP DWMEP DWMEP DWMEP DWMEP 

NAME MHeath AWSmith CBarr CMcKenney BC:LLW 

DATE 9/ 4 /14 9/24/14 9/24/14 9/24/14 9/24/14 

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 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 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 land disposal of low-level radioactive 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. 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) 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 (seven of 11 large tanks and four 

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, the 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, the 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 NRC staff’s visit did not identify any significant issues; however the NRC 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 NRC 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 four large tanks. During the 

visit, the 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. The 

NRC staff documented its results in the observation report (ML12240A037). In June 2014, the 

NRC staff conducted an onsite observation to obtain additional information on disposal actions 

related to closure of the remaining four large tanks at INL. 
- 2 - 

2.0 NRC ONSITE OBSERVATION ACTIVITIES: 

On June 26, 2014, the NRC staff visited the INL site and listened to presentations by DOE 

regarding current and planned closure activities at the INTEC TFF. Mr. Bruce LaRue of the 

Idaho Department of Environmental Quality, DOE provided information regarding start-up of the 

Integrated Waste Treatment Unit (IWTU)1

 that will be used to treat the sodium-bearing waste 

remaining in the remaining four large 1000 m3

 high level waste tanks (tanks WM-186 through 

WM-190), including one spare tank to be cleaned (WM-190). Despite uncertainty in the timing 

of start-up of the IWTU, DOE expects the IWTU will be operational within the year. In the 2012 

onsite observation, DOE discussed tank closure activities including preparations for bulk waste 

removal and residual heel retrieval. Preparations included 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. During the 2014 onsite observation, DOE also indicated 

that it needed to construct above ground transfer lines to be used for sending wash water to the 

INTEC evaporators. DOE also indicated that it updated its tank washing and grouting 

procedures. For example, DOE updated its grouting procedures to address lessons learned 

from previous tank grouting activities. DOE also discussed sequencing of waste retrieval 

operations and constraints on waste processing (e.g., evaporator capacity and schedule 

constraints). DOE also provided a tour of INTEC facilities, including a walk-down of the tank 

farm, and the operations center where remote video surveillance of tank cleaning is conducted. 

2.1 RADIATION PROTECTION: 

2.1.1 Observation Scope:

During the onsite observation, the 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. The NRC staff also obtained information regarding radiological 

controls during washing and grouting operations. DOE provided information on recent worker 

doses associated with tank farm closure activities. Calendar Year 2014 annual collective dose 

at the time of the onsite observation were less than 100 mrem (1 mSv/yr). The dose in 

Calendar Year 2013 was around 300 mrem/yr (3 mSv/yr). Upon NRC’s request, DOE agreed to 

send NRC the Radiation Control Manual and the ALARA procedures. Following the onsite 

observation, DOE provided electronic copies of the documents to NRC. The documents can be 

found in NRC’s Agencywide Documents Access and Management System (ADAMS)2

. The 

NRC staff reviewed the Radiation Control Manual and the procedure for “ALARA Program and 

Implementation” and did not identify any programmatic issues. The NRC staff will continue to 

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

 

1

 In the 2012 onsite observation, the NRC staff was informed that IWTU start-up would be delayed due to 

over-pressurization of the off-gas system during testing. In the 2014 onsite observation, DOE indicated 

that since the 2012 onsite observation, the off-gas system had been redesigned and the IWTU was 

currently going through testing with start-up expected in the fall of 2014. 

2

 ADAMS is the official recordkeeping system through which the NRC provides access to its collecting of 

publicly available documents. ADAMS can be access online at http://www.nrc.gov/reading-im/adams.html. 
- 3 - 

observation or through technical review of documentation such as the Radiation Control 

Manual, radiation work permits, worker dose records, and ALARA documentation as tank farm 

closure activities progress. 

2.1.2 Observation Results: 

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

program. 

2.1.3 Conclusions: 

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

10 CFR 61.43 can be met. 

2.2 ENVIRONMENTAL MONITORING: 

2.2.1 Observation Scope: 

During this onsite observation visit, the NRC staff discussed results of technical reviews related 

to hydrological uncertainties (Key Monitoring Area [KMA] 3 in NRC staff’s INTEC TFF 

monitoring plan (NRC, 2007), and environmental monitoring (KMA 4 in [NRC, 2007]). The NRC 

staff discussed the conclusions of the KMA 3 technical review report. In that report, the NRC 

staff determined that sufficient information had been provided by DOE to close out KMA 3 

related to hydrological uncertainties. For example, DOE prepared a supplemental analysis that 

addressed many of the technical issues identified in the NRC staff’s technical evaluation report 

(NRC, 2006) in this area. In the future, the NRC staff will continue to evaluate routine 

environmental monitoring data under KMA 4. During the onsite observation visit, DOE provided 

the latest tank farm monitoring report, “Fiscal Year 2013 Annual Operations and Maintenance 

Report for Operable Unit 3-14, Tank Farm Soil and INTEC Groundwater”, DOE/ID-11500, Rev. 

0, dated June 2014. This report provides monitoring results for perched water and groundwater 

at the INTEC TFF. The NRC staff will review the report and continue to monitor DOE’s 

environmental monitoring program under KMA 4 in future onsite observations. 

2.2.2 Observation Results: 

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

monitoring program. The NRC staff continues to coordinate with the Idaho Department of 

Environmental Quality and to rely on its oversight of INTEC TFF activities through its 

independent environmental surveillance program. 

2.2.3 Conclusions and Follow-up Actions: 

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

Part 61, Subpart C can be met. 

3.0 PARTICIPANTS: 

NRC Observation Team 

Barr, Cynthia 
- 4 - 

Schwartzman, Adam 

Heath, Maurice 

McKenney, Christepher 

Roberts, Mark 

Idaho Department of Environmental Quality 

LaRue, Bruce 

Partial List of DOE Representatives 

Shaw, Robert (Mark) 

Butterworth, Steve 

Davis, Robert 

Evans, Susan 

Hutchison, David 

Lehrer, Steve 

Long, Jeff 

McCollum, Robyn 

Suttora, Linda 

 
- 5 - 

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.” Revision 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. Available in ADAMS at Accession 

No. 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. Available in ADAMS at Accession No. ML052630012. 

Fiscal Year 2013 Annual Operations and Maintenance Report for Operable Unit 3-14, Tank 

Farm Soil and INTEC Groundwater. Need report No. DOE/ID-IISOU, Revision June 2014. 

Available in ADAMS at Accession No. ML14260A097i

. 

 

i

 ADAMS can be access online at http://www.nrc.gov/reading-rm/adams.html.