INEEL Annual Site Environmental Report - 2002
Chapter 3 - Environmental Program Information

Chapter Highlights
Many environmental programs help implement the environmental compliance policy for the Idaho National Engineering and Environmental Laboratory (INEEL). Most of the regulatory compliance activity is performed through environmental monitoring programs, compliance agreements, the recent Environmental Management Performance Management Plan for Accelerated Cleanup Agreement of the INEEL, the Environmental Restoration Program, and the Waste Management Program.

The major objectives of the environmental monitoring programs conducted at the INEEL are to identify the key contaminants released to the environment, to evaluate different pathways through which contaminants move in the environment, and to determine the potential effects of these contaminants on the public and the environment. This is accomplished through sampling and analysis of air; surface, subsurface, and drinking water; soil; wildlife; and vegetation, as well as measurement of direct radiation. During 2002, the prime Management and Operating (M&O) contractor at the INEEL, Bechtel BWXT Idaho, LLC was responsible for onsite environmental monitoring. The Environmental Surveillance, Education and Research Program contractor, which was a team led by the S. M. Stoller Corporation, was responsible for offsite environmental monitoring.

In May 2002, the U.S. Department of Energy (DOE), the Idaho Department of Environmental Quality (DEQ), and the U.S. Environmental Protection Agency (EPA) signed a letter of intent formalizing an agreement to pursue accelerated risk reduction and cleanup at the INEEL. The intent of accelerating the cleanup of the INEEL yields two significant objectives: (1) risk reduction and continued protection of the Snake River Plain Aquifer and (2) consolidation of Environmental Management activities and reinvestment of savings into cleanup. Nine strategic initiatives were developed around these two objectives to accelerate cleanup.

The Environmental Restoration Program continued progress during 2002 toward final cleanup of contaminated sites at the INEEL. Since the Federal Facility Agreement and Consent Order was signed in December 1991, 22 Records of Decision have been signed and are being implemented; three Remedial Investigation/Feasibility Studies are under development; and more than 70 percent of Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) actions have been completed.

The Waste Management Program provides management services for facility waste streams. The following tasks were accomplished during 2002:

3. ENVIRONMENTAL PROGRAM INFORMATION

This chapter highlights the INEEL environmental programs that help implement the environmental policy for the INEEL (see page iii of this report). Much of the regulatory compliance activity is performed through the various environmental monitoring programs (Section 3.1), the recently signed Accelerated Cleanup Agreement (Section 3.2), the Environmental Restoration Program (Section 3.3), and the Waste Management Program (Section 3.4). Sections 3.5 through 3.7 summarize other significant INEEL environmental programs and activities.

3.1 Environmental Monitoring Programs

Environmental monitoring consists of two separate activities: effluent monitoring and environmental surveillance. Effluent monitoring is the measurement of constituents within a waste stream before its release to the environment, such as the monitoring of stacks or discharge pipes. Environmental surveillance is the measurement of contaminants in the environment. Surveillance involves determining whether or not contaminants are present or measurable in environmental media and, if present, in what concentrations they are found. Surveillance monitoring has several different legal drivers. The monitoring done to comply with with Federal Facility Agreement and Concent Order (FFA/CO) RODs is discussed in Section 3.3.

Effluent monitoring is conducted by various INEEL organizations. Airborne effluent measurements and estimates, required under the Idaho State Implementation Plan, are the responsibility of the regulated facilities. At the INEEL, these facilities include Argonne National Laboratory-West (ANL-W), Central Facilities Area (CFA), Idaho Nuclear Technology and Engineering Center (INTEC), Naval Reactors Facility (NRF), Power Burst Facility/Waste Reduction Operations Complex (PBF/WROC), Radioactive Waste Management Complex (RWMC), Test Area North/Specific Manufacturing Capability (TAN/SMC), and Test Reactor Area (TRA). Descriptions of the airborne effluent monitoring programs are beyond the scope of this document and are not discussed. The Liquid Effluent Monitoring Program and Storm Water Monitoring Program, conducted by the M&O contractor, are designed to demonstrate compliance with the Clean Water Act, Wastewater Land Application Permits, and other water quality permits.

Environmental surveillance is the major environmental monitoring activity conducted at the INEEL. As such, much of the report concentrates on this task. The remainder of this section summarizes environmental monitoring program objectives; the history of environmental monitoring at the INEEL; and information on monitoring of specific environmental media (air, water, agricultural products, animal tissue, and soil), direct radiation, and meteorology.

Results of the environmental monitoring programs for 2002 and additional information on major programs can be found in Chapter 4 (air), Chapter 5 (water), and Chapter 6 (agricultural, wildlife, soil, and direct radiation). Chapter 8 presents 2002 results on current ecological research programs at the INEEL.

Objectives of Environmental Monitoring

Operations of INEEL facilities have the potential to release materials, which may include both radioactive and nonradioactive contaminants, into the environment. These materials can enter the environment through two primary routes: into the atmosphere as airborne effluents and into surface water and groundwater as liquid effluents. Through a variety of exposure pathways (Figure 3-1), contaminants can be transported away from INEEL facilities, where they could potentially impact the surrounding environment and the population living in these areas.

The major objectives of the various environmental monitoring programs conducted at the INEEL are to identify the key pollutants released to the environment, to evaluate different pathways through which pollutants move in the environment, and to determine the potential effects of these pollutants on the public and on the environment.

As discussed previously, monitoring also provides the information to verify compliance with a variety of applicable environmental protection laws, regulations, and permits, described in Chapter 2. The establishment and conduct of an environmental monitoring program at the INEEL is required by the DOE Order 5400.1 (DOE 1993).

The various environmental monitoring programs are also used to detect, characterize, and report unplanned releases; evaluate the effectiveness of effluent treatment, control, and pollution abatement programs; and determine compliance with commitments made in environmental impact statements, environmental assessments, safety analysis reports, or other official DOE documents.

Figure 3-1. Potential exposure pathways to humans from INEEL.

History of Environmental Monitoring

Environmental monitoring has been performed at the INEEL by DOE and its predecessors, the Atomic Energy Commission and Energy Research and Development Agency, as well as by other federal agencies, various contractors, and State agencies since its inception in 1949.

The organization of environmental monitoring programs has remained fairly constant throughout much of the history of the INEEL. The Atomic Energy Commission's Health Services Laboratory, later named the DOE's Radiological and Environmental Sciences Laboratory (RESL), was responsible for conducting most environmental surveillance tasks from the early 1950s to 1993 both on and off the INEEL Site. Contractors operating the various facilities were responsible for monitoring activities performed within the facility boundaries and for effluent monitoring.

Early monitoring activities focused on evaluating the potential of exposing the general public to a release of radioactive materials from INEEL facilities. Radionuclides were the major contaminants of concern because the INEEL was heavily involved in testing nuclear facilities. DOE and its predecessor agencies sampled and analyzed environmental media that could be affected by atmospheric releases. During those early years, the various M&O contractors conducted sampling of liquid and airborne effluents from facilities to develop waste inventory information.

Throughout the history of the Site, the U.S. Geological Survey (USGS) has monitored groundwater quantity and quality in the Snake River Plain Aquifer, with emphasis on the portion of the aquifer beneath the INEEL. The National Oceanic and Atmospheric Administration (NOAA) has monitored weather conditions at the INEEL since the Site's inception.

At the end of 1993, the DOE environmental monitoring program was divided into separate onsite and offsite programs. Responsibility for the onsite program was transferred to the M&O contractor. During 2002, Bechtel BWXT Idaho, LLC was the prime M&O contractor at the INEEL. The offsite monitoring program was transferred to the Environmental Surveillance, Education and Research (ESER) Program contractor. During 2002, the ESER contractor and offsite monitoring activities were performed by a team led by the S. M. Stoller Corporation.

Air Monitoring

Historical Background -Low-volume air samplers have been operated on and in the vicinity of the INEEL since 1952. Table 3-1 lists the areas where samplers have been located and the dates of operation for these samplers (DOE-ID 1991). Before 1960, radiation detection devices, such as a Geiger-Müller tube, were used to record the amount of radioactivity on the filters. Gross beta measurements were made starting in 1960, and by 1967 the present series of analytical measurements were being performed.

High-volume air samplers were operated at the Experimental Field Station (EFS) and CFA from 1973 until October 1996. In 1996, a program evaluation determined that the cost of operating the high-volume samplers was not commensurate with the data being collected, and operations were suspended. Also in 1973, a high-volume sampler began operation in Idaho Falls as part of the EPA's nationwide Environmental Radiation Ambient Monitoring System.

Tritium in atmospheric moisture has been measured at a minimum of two locations since at least 1973. Some limited monitoring may have been performed before this time.

One monitoring location at CFA collected samples of noble gases, with specific interest in krypton-85 (⁸⁵Kr) from approximately 1984 until 1992. This station was used to monitor releases of ⁸⁵Kr from the INTEC during periods when fuel reprocessing was taking place.

Nitrogen dioxide and sulfur dioxide were first monitored for a nine-week period at five onsite locations in 1972. A nitrogen dioxide sampling station operated from 1983 to 1985 to monitor waste calcining operations at INTEC. A sulfur dioxide sampler was also used from 1984 to 1985. The two sampling locations were reactivated in 1988 for nitrogen dioxide, and one station operated from 1989 to 2000 for sulfur dioxide.

The National Park Service, in cooperation with other federal land management agencies, began the Interagency Monitoring of Protected Visual Environments (IMPROVE) program in 1985. This program was an extension of an earlier EPA program to measure fine particles of less than 2.5-µm in diameter (PM_2.5). These particles are the largest cause of degraded visibility. In May 1992, one IMPROVE sampler was established at CFA on the INEEL and a second was located at Craters of the Moon National Monument as part of the nationwide network. Each of the two samplers collected two 24-hour PM_2.5 samples a week. Analyses were performed for mass, optical absorption, hydrogen, carbon, nitrogen, oxygen and the common elements from sodium through lead on the periodic table. Operation of the CFA sampler ceased in May 2000 when the EPA removed it from the nationwide network.

Current Programs -Both the ESER and M&O contractors maintain a network of low-volume air samplers to monitor for airborne radioactivity (Figure 3-2). The ESER contractor operates 12 samplers at offsite locations and three onsite samplers. The ESER contractor added a thirteenth offsite sampler in June 2001 at Jackson, Wyoming, in response to public concerns. Two samplers were also moved to two new locations in July 2001 when the leases at the previous stations were terminated by the landlords. The sampler at Blackfoot was moved to Dubois and the sampler at Reno Ranch/Birch Creek was moved to Blue Dome. The M&O contractor maintains 13 onsite and four offsite sampling locations.

Figure 3.2. ESER and M&O contractor low-volume radiological air sampling locations.

Each low-volume air sampler maintains an average airflow of 50 L/min (2 ft³/min) through a set of filters consisting of a 1.2-µm pore membrane filter followed by a charcoal cartridge. The membrane filters are 99 percent efficient for airborne particulates with an aerodynamic diameter of 0.32-µm, and higher for larger diameter particulates.

Filters from the low-volume air samplers are collected and analyzed weekly for gross alpha and gross beta activity. Charcoal cartridges are analyzed for iodine-131 (¹³¹I) either individually or in batches of up to nine cartridges. During batch counting, if any activity is noted in a batch, each cartridge in that batch is analyzed individually.

Particulate filters are analyzed weekly using a proportional counting system. Filters are analyzed after waiting a minimum of four days to allow naturally occurring radon progeny to decay. Gross alpha and beta analyses are used as a screening technique to provide timely information on levels of radioactivity in the environment.

Specific radionuclide analyses are more sensitive than gross alpha and gross beta analyses for detecting concentrations of human-made radionuclides in air. The particulate filters of the low-volume samplers are composited by location at the end of each quarter, and all composites are analyzed for specific radionuclides by gamma spectrometry. Composites are then submitted for analyses for specific transuranic radionuclides (americium-241 [²⁴¹Am], plutonium-238 [²³⁸Pu], plutonium-239/240 [^239/240Pu]), and for strontium-90 [⁹⁰Sr]).

Measurements of suspended particulates are also performed on the 1.2-µm pore membrane filters from the low-volume air samplers. The M&O contractor weighs their filters weekly before and after sampling to determine the amount of material collected. The ESER contractor also weighs their filters weekly before and after use. In both cases, the amount of material collected is determined by subtracting the pre-sampling (clean filter) weight from the postsampling (used filter) weight. The concentration of suspended particulates is calculated by dividing the amount of material collected on the filters by the total volume of air that passed through the filters.

The EPA uses a standard for concentrations of particles with an aerodynamic diameter less than or equal to 10 microns (PM₁₀). The ESER contractor maintains PM₁₀monitors at the Rexburg and Blackfoot Community Monitoring Stations. The M&O contractor operates PM₁₀monitors at various facilities at the INEEL.

Samplers for tritium in atmospheric moisture are located at two onsite and four offsite locations. In these samplers, air is pulled through a column of desiccant material (i.e., silica gel or molecular sieve) at 0.3-0.5 L/hr (0.6-1.0 ft³/hr). The material in the column absorbs water vapor. Columns are changed when sufficient moisture to obtain a sample is absorbed (typically from one to three times per quarter). The absorbed water is removed from the desiccant through heat distillation. Tritium concentrations are then determined from the absorbed water (distillate) by liquid scintillation counting. Atmospheric concentrations are determined from the tritium concentration in the distillate, quantity of moisture collected, and the volume of air sampled.

Tritium is also monitored using precipitation samples collected on the INEEL monthly at CFA and weekly at the EFS. A monthly sample is also obtained offsite in Idaho Falls. Each precipitation sample is submitted for tritium analysis by liquid scintillation counting. A portion of the monthly sample collection at Idaho Falls is sent to EPA for analysis and reporting in the Environmental Radiation Ambient Monitoring System (ERAMs) at http://www.epa.gov/narel/erams/.

Nitrogen oxides continue to be monitored at two stations on the INEEL (Van Buren Gate and EFS). The IMPROVE sampler station at Craters of the Moon continued operation through 2002.

Water Monitoring

Historical Background -The USGS has conducted groundwater studies at the INEEL since the Site's inception in 1949. The USGS was initially assigned the task to characterize water resources of the area. It has since maintained a groundwater quality and water level measurement program on the INEEL to support research and monitor the movement of radioactive and chemical constituents in the Snake River Plain Aquifer. The first well, USGS 1, was completed and monitored in December 1949. USGS personnel have maintained an INEEL Project Office at CFA since 1958 (USGS 1998).

In 1993, the DOE Idaho Operations Office (DOE-ID) initiated a program to integrate all of the various groundwater monitoring programs on the INEEL. This resulted in the development of the INEL Groundwater Monitoring Plan (DOE-ID 1993a) and the INEL Groundwater Protection Management Plan (DOE-ID 1993b). The monitoring plan described historical conditions and monitoring programs, and it included an implementation plan for each facility. The protection management plan established policy and identified programmatic requirements.

Sampling and analysis of drinking water both onsite and offsite began in 1958. Analysis for tritium began in 1961. Up to 28 locations were sampled before increased knowledge of the movement of groundwater beneath the INEEL led to a decrease in the number of sampling locations.

A program to monitor lead and copper in drinking water in accordance with EPA regulations has been in place since 1992. Three successive years of monitoring lead and copper levels in drinking water were concluded in 1995. Since regulatory values were not exceeded, this monitoring has been reduced to once every three years beginning in 1998.

As one of the requirements of the National Pollutant Discharge Elimination System General Permit effective October 1, 1992, the INEEL was obligated to develop a storm water monitoring program. Sampling of snowmelt and rain runoff began in 1993, and it included 16 sites at eight INEEL facilities. Samples were collected from storms of at least 0.25 cm (0.1 in.) of precipitation preceded by a minimum of 72 hours without precipitation (63 FR 189 1998).

In September 1998, the EPA issued the "Final Modification of the National Pollutant Discharge Elimination System Storm Water Multi-Sector General Permit for Industrial Activities" (63 FR 189 1998). The permit requires sample collection and laboratory analysis twice during every five-year cycle at potential discharge locations. This usually occurs during years two and four; the INEEL last collected and analyzed storm water samples in 2002. The permit also required continued annual monitoring from coal piles at INTEC whenever there was a discharge to the Big Lost River System. In addition, quarterly visual monitoring was required at all other designated locations.

Current Programs -USGS personnel collect samples from 178 observation or production wells and auger holes and have them analyzed for selected organic, inorganic, and radioactive substances. Sampling is performed on schedules ranging from monthly to annually. These samples are submitted to the RESL at CFA for analysis of radioactive substances and to the USGS

National Water Quality Laboratory in Lakewood, Colorado, for analysis of organic and inorganic substances. The USGS also records water levels at 308 selected wells on schedules ranging from monthly to annually.

The USGS also conducts special studies of the groundwater resources of the Eastern Snake River Plain. The abstract of each study published in 2002 is provided in Appendix C. These special studies provide more specific geological, chemical, and hydrological information on the characteristics of the aquifer and the movements of chemical and radiochemical substances in the groundwater. One special USGS investigation of particular interest is the ongoing annual sampling effort in the area between the southern boundary of the INEEL and the Twin Falls/Hagerman area, known as the Magic Valley Study. This study was prompted by public concern that radiochemical and chemical constituents generated by INEEL facilities could migrate through the Snake River Plain Aquifer to the Snake River in the Twin Falls/Hagerman area. The most recent results of this study are summarized in USGS Open File Report 03-168 (Twining et al. 2003).

The INEL Groundwater Monitoring Plan was updated in 2002 to include the monitoring wells, constituent lists, and sampling frequencies of current programs. The updated plan (DOE-ID 2002) does not replace the 1993 plan but uses it as the basis for the information previously presented regarding operational history, contaminant sources, and monitoring networks for each INEEL facility. The updated plan modifies groundwater monitoring recommendations in accordance with more recent requirements in records of decisions, relying on existing multiple groundwater programs rather than a single comprehensive program.

The M&O contractor conducts groundwater monitoring in support of state of Idaho Wastewater Land Application Permit requirements at INTEC and TAN as well as surveillance monitoring at INTEC. In 2002, this included collecting 234 groundwater samples yielding 482 parameter results. ANL-W also performs groundwater surveillance monitoring in support of the Record of Decision (ROD) and a submitted state of Idaho Wastewater Land Application Permit.

The M&O contractor's Drinking Water Program monitors production and drinking water wells for radiological, chemical, and bacteriological contaminants at all their INEEL facilities. Currently, 17 wells and ten distribution systems are monitored. All analyses for the program are conducted using laboratories certified by the state of Idaho or laboratories certified in other states, where this certification is accepted by the state of Idaho. The NRF and ANL-W maintain separate programs for sampling drinking water based on the requirements applicable at their facilities. Radiological and bacteriological samples from ANL-W are sent to the M&O contractor for analysis. ANL-W conducts a separate program for chemical monitoring.

M&O personnel collect quarterly onsite drinking water samples from active systems for radiological analysis. Paragon Laboratory, located in Fort Collins, Colorado, performed these analyses during 2002. Each water sample is submitted for gross analyses for alpha- and beta-emitting radionuclides. Tritium analyses are also performed on all drinking water samples. Strontium-90 analyses are performed on quarterly samples from CFA and INTEC because some water quality monitoring data indicate this water may contain ⁹⁰Sr concentrations above background levels.

The INEEL Environmental Hygiene Laboratory analyzes drinking water monthly for coliform bacteria. At the end of 2002, this lab temporarily lost its State accreditation and bacteria samples were sent to Microwise in Idaho Falls. If indications of contamination by bacteria are found in a sample, that particular drinking water system is taken out of service until it can be disinfected, resampled, and tested again until it is clear of bacteria. Corrective actions to purify the water may vary among facilities.

The M&O contractor's Drinking Water Program also samples drinking water from wells and distribution systems at INEEL facilities for volatile organic compounds. Chlorinated drinking water systems are also monitored for total trihalomethanes (bromoform, bromodichloromethane, chloroform, and dibromochloromethane). Additional sampling is conducted for a variety of inorganic constituents, including metals, nitrates, and dissolved solids.

Storm water from the coal piles at INTEC did not discharge to the Big Lost River System in 2002; therefore, analytical monitoring was not required. Thus, monitoring in 2002 consisted only of quarterly visual monitoring at 18 locations and analytical monitoring at two RWMC locations.

The ESER contractor collects drinking water samples semiannually from boundary and distant communities. Surface water samples are collected from springs in the Twin Falls/Hagerman area and the Snake River at Idaho Falls and Bliss. Each water sample is analyzed for gross alpha and gross beta activity, and tritium.

Agricultural Products and Vegetation Monitoring

Historical Background -Milk was the first agricultural product to be monitored beginning in at least 1957. The number of samples collected per year has been relatively constant since about 1962. Because of improvements in counting technology, the detection limit for ¹³¹I has decreased from about 15,000 pCi/L in early sampling to the current detection level of about 2 pCi/L.

Wheat was first sampled as part of the radioecology research program in about 1962. The current monitoring program dates back to 1963. Potatoes were first collected in 1976 as part of an ecological research project. Regular potato sampling was resumed in 1994 in response to public concern. Lettuce has been collected since 1977.

Current Programs -Milk samples are collected from both commercial and single-family dairies. A 2-L (0.5-gal) sample is obtained from each location monthly, except in Idaho Falls where a sample is collected weekly. Milk from each location is analyzed for ¹³¹I, and one analysis for ⁹⁰Sr and tritium at each location is performed during the year.

Wheat samples are collected from grain elevators in the region surrounding the INEEL. All wheat samples are analyzed for ⁹⁰Sr and gamma-emitting radionuclides.

Potato samples are collected from storage warehouses in the vicinity of the INEEL, with three to five samples from distant locations. The potatoes, with skins included, are cleaned and weighed before processing. All potato samples are analyzed for ⁹⁰Sr and gamma-emitting radionuclides.

Lettuce samples are obtained from private gardens in communities in the vicinity of the INEEL. Samples are washed to remove any soil as in normal food preparation, dried, reduced to a powdered form, and weighed. All lettuce samples are analyzed for ⁹⁰Sr and gamma-emitting radionuclides.

The M&O contractor annually collects perennial and grass samples from around the major waste management facilities. These samples are analyzed for gamma-emitting radionuclides. ANL-W also collects vegetation samples annually from around the Industrial Waste Pond and along the Industrial Waste Ditch. These samples are analyzed for selected alpha, beta, and gamma radionuclides.

Animal Tissue Monitoring

Historical Background -Monitoring of game animals has focused on research into the movement of radionuclides through the food chain. Rabbit thyroids and bones were first sampled in 1956. In 1973, routine sampling of game animal tissues was instituted; the first studies on waterfowl that were using waste disposal ponds containing various amounts of radionuclides occurred the following year. Waterfowl studies have covered the periods 1974-1978, 1984-1986, and 1994-present. In 1998, the collection of waterfowl became part of the regular surveillance program.

Mourning doves were collected in 1974 and 1975 as part of a radioecology research project. Routine dove sampling as part of the environmental surveillance program was initiated in 1996.

Sheep that have grazed onsite have been part of the routine monitoring program since a special study was conducted in 1975. Beef cattle were also monitored biennially during the period 1978 to 1986.

Yellow-bellied marmots were first collected in 1998 as part of a special study initiated in response to concerns by Native Americans, who hunt and consume them. They were monitored again in 2000.

Current Programs -Muscle, liver, and thyroid are collected from game animals accidentally killed on INEEL roads. Thyroid samples are placed in vials and analyzed by gamma spectrometry specifically for ¹³¹I. Muscle and liver samples are processed, placed in a plastic container, and weighed before gamma spectrometry analysis.

Waterfowl samples are collected from waste disposal ponds at four facilities on the INEEL. Control samples are also taken in areas distant from the INEEL. Waterfowl samples are separated into an external portion (consisting of the skin and feathers); edible portion (muscle, liver, and gizzard tissue); and remainder portion. All samples are analyzed by gamma spectrometry. Selected samples are also analyzed for ⁹⁰Sr and transuranic radionuclides.

Mourning doves are collected from the vicinity of INTEC and TRA waste ponds and from a control area distant to the INEEL. Because of the small size of a typical dove, muscle tissues from several doves collected at the same location are composited into one sample. Samples are analyzed for gamma-emitting radionuclides, ⁹⁰Sr, and transuranic radionuclides.

Sheep are sampled from grazing areas on the INEEL and from control areas offsite. Muscle and liver samples are collected and analyzed for gamma-emitting raionuclides. Thyroid samples are analyzed by gamma spectrometry for ¹³¹I.

Marmots are collected from the RWMC and from a control location. Muscle, viscera, and hair-skin/bone samples are analyzed for transuranic radionuclides and ⁹⁰Sr.

Soil Monitoring

Historical Background -Soil sampling has been included as part of routine monitoring programs since the early 1970s, although some limited soil collection was performed around various facilities as far back as 1960. Offsite soil sampling at distant and boundary locations was conducted annually from 1970 to 1975. The collection interval was extended to every two years starting in 1978. Soil samples in 1970, 1971, and 1973 represented a composite of five cores of soil 5 cm (2-in.) in depth from a 1-m²(approximately 10 ft ²) area. In all other years, the five cores were collected from two depths 0-5 cm (0-2 in.) and 5-10 cm (2-4 in.) within a 100-m²(~1076 ft²) area.

A soil sampling program began in 1973 around onsite facilities. Soils at each facility were sampled every seven years. In 2001, all locations were sampled as the frequency was increased to every two years.

Current Programs -Twelve offsite locations are sampled by the ESER program in even numbered years. Following collection, soil samples are dried for at least three hours at 120^°C (250^°F) and sieved. Only soil particles less than 500-µ in diameter (35 mesh) are analyzed. All offsite samples are analyzed for gamma-emitting radionuclides, ⁹⁰Sr, and transuranic radionuclides.

The M&O contractor now performs soil sampling on a two-year rotation. One hundred one sites were sampled in 2002. All sites are analyzed insitu for gamma emitting radionuclides and ⁹⁰Sr. Approximately 10 percent of the sites have a physical sample collected for laboratory analysis of gamma-emitting and transuranic radionuclides. Samples are collected from 0-5 cm (0-2 in.) and sieved at the sample site with the 35-mesh fraction being collected. The M&O contractor also performs annual sampling of the CFA sewage treatment plant irrigation spray field to show compliance with the Wastewater Land Application Permit soil loading limits.

ANL-W collects soil samples annually at locations along the major wind directions and at crosswind locations. Samples are analyzed for low-level gamma-emitting radionuclides and uranium, plutonium, and thorium isotopes. Sufficient material to fill a 500 mL (16 oz.) wide mouth jar is collected from 0-5 cm (0-2 in.) depth within an approximately 1-m²(~10-ft²) area.

Direct Radiation Monitoring

Historical Background -Measurements of radiation in the environment have been made on the INEEL since 1958. The technology used for radiation measurements at fixed locations has evolved from film badges to thermoluminescent dosimeters (TLDs). In addition to these locations, surveys using hand-held and vehicle-mounted, radiation instruments have been conducted since at least 1959. Aerial radiological surveys were also performed in 1959, 1966, 1974, 1982, and 1990.

Current Programs -Environmental TLDs are used to measure ambient ionizing radiation exposures. The TLDs measure ionizing radiation exposures from all external sources. External sources include natural radioactivity in the air and soil, cosmic radiation from space, fallout from nuclear weapons tests, radioactivity from fossil fuel burning, and radioactive effluents from INEEL operations and other industrial processes.

At each location, a dosimeter holder containing four individual chips is placed 1 m (3 ft) above ground level. The M&O contractor maintains dosimeters at 13 offsite locations and 135 locations on the INEEL. The ESER contractor has dosimeters at 14 offsite locations. The dosimeter card at each location is changed semiannually, and cumulative gamma radiation is measured by the M&O contractor Dosimetry Unit.

In addition to TLDs, the M&O contractor uses a mobile global positioning system radiometric scanner arrangement to conduct gamma radiation surveys. Two plastic scintillation detectors and radiometric and global positioning system equipment are mounted on a four-wheel drive vehicle. The vehicle is driven slowly across the area to be surveyed while radiometric and location data are continuously recorded.

ANL-W conducts annual surface radiation surveys of wastewater ditches using handheld portable beta-gamma meters.

Meteorological Monitoring

Historical Background -The NOAA Air Resources Laboratory-Field Research Division (NOAA ARL-FRD) began work at the INEEL in 1948 as a Weather Bureau Research Station. The first meteorological observation station established to support the Site began operation in 1949 at CFA. The network of stations expanded in the 1950s to provide more closely spaced data. The current mesonet was designed and constructed in the 1990s.

Current Programs -NOAA ARL-FRD currently maintains a network of 36 meteorological stations in the vicinity of the INEEL. These stations provide continuous measurements of a variety of parameters, including air temperature at two or three elevations, wind direction and speed, relative humidity, barometric pressure, solar radiation, and precipitation. In addition, continuous measurements of wind speed/direction and air temperature at various heights above the ground are taken using a wind profiling system and a radio acoustic sounding system located on the INEEL. Data are transmitted via radio and telephone to the NOAA ARL-FRD Idaho Falls facility, where they are stored in a computerized archive.

Monitoring and Surveillance Committee

The INEEL Monitoring and Surveillance Committee was formed in March 1997 and holds bimonthly meetings to coordinate activities between groups involved in INEEL-related onsite and offsite environmental monitoring. This standing committee brings together representatives of DOE (Idaho, Chicago, and Naval Reactors); INEEL contractors; ANL-W; NRF; ShoshoneBannock Tribes; Idaho INEEL Oversight Program; NOAA; and USGS. The Monitoring and Surveillance Committee has served as a valuable forum to review monitoring, analytical, and quality assurance methodologies; to coordinate efforts; and to avoid unnecessary duplication.

Monitoring Summary

Tables 3-2 through 3-5 present a summary of the environmental surveillance programs conducted by the ESER contractor, the M&O contractor, ANL-W, and the USGS, respectively, in 2002.

Table 3-2. ESER environmental surveillance program summary (2002).

Table 3-3. M&O contractor site environmental surveillance program summary (2002).

Table 3-4. ANL-W site environmental surveillance program summary (2002).

Table 3-5. U.S. Geological Survey monitoring program summary (2002).

3.2 Accelerated Cleanup of the INEEL

In May 2002, DOE, the DEQ, and the EPA signed a letter of intent formalizing an agreement to pursue accelerated risk reduction and cleanup at the INEEL. The letter provides the foundation for a collaborative plan for the accelerated cleanup of the INEEL.

The DOE-ID and its contractors, in consultation with the state of Idaho and EPA, developed the EM Performance Management Plan for Accelerated Cleanup of the INEEL describing the approach to accelerate the reduction of environmental risk at the INEEL by completing its cleanup responsibility faster and more efficiently. The plan will fulfill the following two visions:

By 2012, the INEEL will have achieved significant risk reduction and will have placed materials in safe storage ready for disposal.
By 2020, the INEEL will have completed all active cleanup work with potential to further accelerate cleanup to 2016.

The vision for accelerating cleanup of the INEEL results in two objectives: (1) risk reduction and continued protection of the Snake River Plain Aquifer and (2) consolidation of Environmental Management activities and reinvestment of savings into cleanup.

Nine strategic initiatives were developed around these objectives to accelerate cleanup. They include:

Accelerate Tank Farm Closure;

Accelerate high-level waste calcine removal from Idaho;

Accelerate consolidation of spent nuclear fuel to the INTEC;

Accelerate offsite shipments of transuranic waste stored in the transuranic waste storage area;

Accelerate remediation of miscellaneous contaminated areas;

Eliminate onsite treatment and disposal of low-level and mixed low-level waste;

Transfer all Environmental Management-managed special nuclear material offsite;

Accelerate consolidation of INEEL facilities and reduce footprint. .

At the 2020 end state, some activities will continue: shipment of spent nuclear fuel to a repository; retrieval, treatment, packaging, and shipment of calcined high-level waste to a repository; and final dismantlement of remaining Environmental Management buildings. These activities will be complete by 2035 with the exception of some minor activities leading to long-term stewardship (see Section 3.4). Even with these continuing activities, the cleanup costs can be reduced by up to $19 billion, and the cleanup schedule can be completed decades earlier. The Performance Management Plan is a living document that will be revised and improved as necessary to reflect the decisions and progress made toward accelerated cleanup.

3.3 Environmental Restoration Program

Since the FFA/CO was signed in December 1991, the INEEL has cleaned up sites containing asbestos, petroleum products, acids and bases, radionuclides, unexploded ordnance and explosive residues, polychlorinated biphenyls (PCBs), heavy metals, and other hazardous materials. The INEEL Environmental Restoration Program continued progress toward final cleanup of contaminated sites at the INEEL during 2002. Cleanup of this contamination is being conducted under the CERCLA. By the end of 2002:

Twenty-two RODs have been signed and are being implemented;

Three Remedial Investigation/Feasibility Studies (RI/FSs) are under development; and

More than 70 percent of CERCLA remedial actions are complete.

Comprehensive RI/FSs have been completed for Waste Area Groups (WAGs) 1, 2, 3, 4, 5, 8, 9, and 10. The comprehensive RI/FSs, which take an average of 40 months to complete, accomplish the following:

Determine the cumulative risks for an entire WAG by assessing the combined impact of all release sites within that group;

Review assumptions used in each previous investigation, including "No Further Action" sites, Track 1 and 2 limited field investigations, RI/FSs, and interim actions;

Identify data gaps and recommend actions, such as field sampling or historical document research, to resolve questions;

Perform feasibility studies to evaluate remedial alternatives for the entire WAG;

Develop proposed plans presenting the alternatives and recommending a preferred alternative; and

Develop RODs selecting the alternative and resolving public comments.

The general procedure for all comprehensive investigations begins with developing a work plan outlining potential data gaps and release sites that may require more field sampling. When the investigation is complete, DOE, EPA and the State hold public comment meetings on the proposed cleanup alternative. A complete catalog of documentation associated with the INEEL Environmental Restoration Program is contained in the CERCLA Administrative Record at http://ar.inel.gov/.

Waste Area Group 1 - Test Area North

In 2002, the agencies started development on an amendment to the Operable Unit 1-10 ROD which will select a new remedy for the V-tanks. The originally selected remedy included removing and shipping of the tank contents to an out-of-state treatment facility. The treated tank contents, contaminated soils, and the tanks were to be disposed at the WAG 3 INEEL CERCLA Disposal Facility or other acceptable facility. The out-of-state treatment facilities are no longer available and there are no other out-of-state treatment facilities capable of directly treating the tanks' contents. Therefore, the agencies have agreed to amend the ROD to reevaluate several new and previously considered remedies.

A technology evaluation completed in 2002 considered the feasibility and reliability of two dozen potential technologies, including all that were evaluated during the original 1997 feasibility study for this site. The results of this evaluation will be published in 2003, after which a new plan for remediating this site will be developed. WAG 1 continued treatment and monitoring of groundwater, with more than 450 million L (119 million gal) treated in 2002.

Waste Area Group 2 - Test Reactor Area

Remediation activities at WAG 2 are nearly complete. In 2002, investigation continued of newly identified sites that may contain contamination. Institutional controls were maintained and an annual inspection report was published.

Waste Area Group 3 - Idaho Nuclear Technology and Engineering Center

The following accomplishments were achieved at the WAG 3 in 2002:

The new percolation ponds were put into service 16 months ahead of the FFA/CO schedule.

Located just over 3.2 km (2 mi) southwest of the INTEC, these ponds replace the older ponds that were closer to the facility and were a source of water that could potentially transport contaminants underneath the INTEC downward to the aquifer. A groundwater sampling program at INTEC confirmed that relocation of the percolation ponds is slowly reducing the perched water below the facility;

Completed construction of the INEEL CERCLA Disposal Facility Landfill Cell 1 and Evaporation Ponds, and

Submitted the Operable Unit 3-13 Other Surface Soils (Group 3) draft Prioritization and Site Grouping Report for agency review on May 24, 2002, ahead of the May 26, 2002, enforceable milestone date.

EPA issued a Notice of Violation to DOE-ID on December 9, 2002, for failing to submit a complete Remedial Action Report for Operable Unit 3-1, Group 1, by the established FFA/CO deadline. The State, EPA, and DOE-ID will resolve this issue through formation of a Dispute Resolution Committee comprised of representatives from each of the agencies.

Waste Area Group 4 - Central Facilities Area

Cleanup activities at the WAG 4 are nearly complete. The following accomplishments were achieved at the WAG 4 in 2002:

Removed sewage drainfield components and soil, and nearly completed the drainfield cover; and

Removed lead-contaminated soils from transformer yard for offsite disposal.

Waste Area Group 5 - Power Burst Facility/Waste Reduction Operations Complex

Cleanup activities at the WAG 5 are nearly complete. The following accomplishments were achieved at the WAG 5 in 2002:

Completed final remediation of the sanitary waste system and an underground tank containing radionuclides and PCBs, which included removing or abandoning four inactive waste system sites;

Completed the first phase of cleanup at the ARA; and

Completed removal of numerous mixed waste incinerator components.

Waste Area Group 6/10 - Experimental Breeder Reactor No. 1/ Boiling Water Reactor Experiment, Miscellaneous Sites, Snake River Plain Aquifer

The following accomplishments were achieved at the WAG 6/10 in 2002:

Transmitted the draft Operable Unit 10-08 RI/FS work plan to the DOE-ID for transmittal to the agencies in March;

Transmitted the Draft Record of Decision for EBR-I/Boiling Water Reactor Experiment (BORAX) Areas and Miscellaneous Sites to the agencies in April;

Completed draft ROD for the EBR-I/BORAX areas and miscellaneous sites;

Submitted ROD for the comprehensive examination of impacts on the Snake River Plain Aquifer and miscellaneous sites, which incorporated the public's suggestion to prioritize higher-risk sites so they are addressed first;

Submitted draft RI/FS Work Plan for Sitewide groundwater;

Submitted draft final OU 10-04 Comprehensive RI/FS ROD to agencies for review in July;

Completed the work plan for the cleanup investigations of INEEL Sitewide groundwater contamination; and

Completed a report on conceptual models of subsurface contaminant transport in the INEEL subsurface.

Waste Area Group 7 - Radioactive Waste Management Complex

The WAG 7 also includes the Subsurface Disposal Area (SDA), a 39-ha (97 acre) disposal area containing buried hazardous and radioactive waste. Organic solvents contained in this waste are a source of groundwater contamination and are being removed by an ongoing cleanup action. Projects are currently underway to gain more information about the contents of the pits and trenches of the SDA to aid decision-makers in determining the best treatment technology. The following accomplishments were achieved at the WAG 7 in 2002:

Continued the Organic Contamination in the Vadose Zone Project, which vacuums solvent vapors that have escaped from buried waste. The vapors are brought to the surface and destroyed using thermal and catalytic processes. Since the beginning of operations in January 1996, more than 61,689 kg (136,000 lb) of these contaminants have been removed and destroyed, including more than 38,500 kg (~85,000 lb) of carbon tetrachloride; and
Ongoing studies identified several different remediation options for the entire SDA, including transurance, mixed, and low-level radioactive waste.

In 2002, the State, EPA, and DOE-ID agreed on new enforceable deadlines for both Pit 9 and the comprehensive RI/FS for the SDA. The agencies also agreed on a revised technical approach, the Glovebox Excavator Method or GEM project to demonstrate retrieval from a small ara. This limited demonstration will be followed by a complete remediation of Pit 9, called the Stage III project.

At GEM, workers will remotely excavate wastes and examine them in a shielded confinement structure or glovebox. The glovebox operates under negative air pressure to prevent contamination from escaping. The waste will be treated for shipment to the WIPP. Construction was initiated in 2002 for the glovebox excavator, four months ahead of schedule, and it was 45 percent complete by the end of the calendar year. The GEM project will retrieve 57 to 96 m³(75 to 125 yd³) of waste buried in a portion of the 0.4 ha (1-acre) Pit 9 and sample the underlying soils. Excavation could begin as early as September 2003.

New enforceable deadlines established for Pit 9 resulted in new enforceable deadlines for the comprehensive investigation. The revised schedule calls for the draft remedial investigation and baseline risk assessment by August 31, 2005; the draft feasibility study by December 31, 2005; and the draft ROD by December 31, 2006.

Waste Area Group 8 - Naval Reactors Facility

NRF receives and inspects spent nuclear fuel from defense activities. Remote-handled low-level waste from these operations is currently sent to the RWMC for disposal. The following accomplishment was achieved at the WAG 8 in 2002:

Completed Phase I remedial actions at three of the remaining five sites of concern.

Waste Area Group 9 - Argonne National Laboratory-West

ANL-W has a long history in nuclear technology, including the development of instruments for assaying transuranic waste. In addition to being a partner in nuclear energy research and development, ANL-W facilities and expertise are used to support INEEL's management of transuranic waste.

Contaminated sites at ANL-W include tanks and wastewater handling/disposal systems, such as ditches and ponds. DOE has been testing the use of plants to remove both radioactive and nonradioactive constituents from contaminated soils at several sites at ANL-W. The results are promising and have been supported through additional testing. Soil verification sampling, scheduled for 2003, is expected to show these sites have met their remediation goals. The following accomplishment was achieved at WAG 9 in 2002:

Continued phytoremediation program.

The end of calendar year 2002 marked the fourth year of phytoremediation. The DOE Chicago Operations Office believes the remediation goals have been met at each of the sites, thereby excluding the need to continue with phytoremediation. Soil sampling will be performed in 2003 to confirm this.

CERCLA Public Health Assessment

The Agency for Toxic Substances and Disease Registry is conducting a public health assessment of the INEEL as required by CERCLA for all sites on the National Priorities List. The focus of the public health assessment is to provide information that will further the goal of preventing and mitigating exposures to hazardous substances released to the environment. A draft of the public health assessment was submitted to interested federal, State, and Tribal government agencies for review in 2002. After these reviews are completed, the Agency will release a draft for public review and comment.

3.4 INEEL Long-term Stewardship Program

Completing the remediation activities at the INEEL in compliance with the regulatory agreements governing them will result in residual contamination remaining at some locations onsite. The sites where residual contaminants remain will require long-term stewardship (LTS) to prevent unacceptable contact between waste residue and the public and to initiate subsequent cleanup activities in the event of an unforeseen increase in contaminant transport through the soil or groundwater. The term LTS refers to all activities necessary to protect human health and the environment following completion of remediation, disposal, or stabilization of a site or a portion of a site. The INEEL considers the scope of LTS to also include conserving ecological and cultural resources and maintaining awareness of changes in technology, regulations, and policy affecting these stewarded sites.

While LTS activities such as monitoring groundwater, conducting surveillance of remedies and maintenance of caps and landfills, and restricting access to residually contaminated sites have been conducted for years at the INEEL under the auspices of several different programs, DOE recognized that management advantages could be gained by consolidating these similar activities into one program. In fiscal year 2000, DOE-ID developed a schedule for creating an INEEL LTS Plan, which would describe the strategic and tactical elements of a consolidated LTS Program at the INEEL. Creation of an LTS Program represents a management consolidation of postremediation responsibilities, regardless of what law or agreement governs the remedy. Consolidating these activities does not change any agreed-upon obligations for the operation, maintenance, monitoring, institutional control, or post-closure care identified in RODs, Hazardous Waste Management Act/Resource Conservation and Recovery Act (RCRA) closure plans, or other agreements. Rather, creation of the INEEL LTS Program is a way to implement post-remediation responsibilities agreed to under a variety of regulations in a more efficient and focused manner.

Development of INEEL LTS Plan

The INEEL LTS Plan (DOE 2002) consists of two parts: (1) a strategic portion, in which the overall vision, mission, objectives, and goals of the program will be captured and (2) a tactical portion, which will document the specific activities and schedules necessary to achieve the vision, mission, objectives, and goals.

In 2002, an LTS Strategic Plan was developed. Regulators, environmental advocates, State and local governments, federal and State land and resource management agencies, the Shoshone-Bannock Tribes, and the general public helped develop the vision, mission, and objectives of the INEEL LTS Program that forms the foundation of the INEEL LTS Strategic Plan. The INEEL LTS Implementation Plan, identifying the tactical activities necessary for achieving the strategic elements, will be developed in fiscal year 2003. Combined, the two documents will constitute the INEEL LTS Plan.

3.5 Waste Management Program

The mission of the Waste Management Program (WMP) at the INEEL is to provide safe, compliant, and cost-effective management services for facility waste streams. Safe operations and compliance with federal, State, and local regulations are the highest priorities along with meeting the commitments made in the Idaho Settlement Agreement and the INEEL Site Treatment Plan. The main goals of the program are to reducing the total amount of wastes generated and to dispose of wastes.

Federal Facility Compliance Act

The Federal Facility Compliance Act requires the preparation of a site treatment plan for the cleanup of mixed wastes (those containing both radioactive and nonradioactive hazardous materials) at the INEEL.

In accordance with the final Site Treatment Plan, the INEEL began receiving offsite mixed waste for treatment in January 1996. The INEEL received mixed waste from other sites within the DOE complex including Hanford, Los Alamos, Paducah, Pantex, Sandia, and six locations managed by the Office of Naval Reactors. The INEEL stopped receiving offsite mixed waste for treatment at the Waste Experimental Reduction Facility (WERF) in 2000. The INEEL is storing the backlog of mixed waste in Resource Conservation and Recovery Act-permitted storage at WROC and INTEC. Disposal of the backlog mixed waste will occur by no later than 2006.

Treatment of the majority of the offsite waste was performed at the WROC until fiscal year 2000 using incineration, stabilization, neutralization, and carbon absorption technologies. Disposition of INEEL-generated mixed waste will be obtained from offsite commercial treatment and disposal vendors. Other offsite mixed wastes may be treated at the Advanced Mixed Waste Treatment Project Facility.

During 2002, seven Site Treatment Plan milestones were met:

Commercial treatment backlog 207 m³(7310 ft ³);

High-Level Waste Evaporator processing 644 m³(22,743 ft³);

Mercury waste shipment offsite;

The ANL-W Sodium Components Maintenance Shop treated a backlog of 2.4 m³(85 ft³);

High-efficiency particulate air filter leach backlog treatment of 4.5 m³(159 ft³) of backlogged filters;

Debris treatment begin operation; and

Advanced Mixed Waste Treatment Project, begin system testing.

Advanced Mixed Waste Treatment Project

The overall goal of the Advanced Mixed Waste Treatment Project is the treatment of alpha-containing low-level mixed and transuranic (TRU) wastes for final disposal by a process that minimizes overall costs while ensuring safety. This will be accomplished through a private sector treatment facility with the capability to treat specified INEEL waste streams and the flexibility to treat other INEEL and DOE regional and national waste streams. The facility will treat waste to meet the most current requirements; reduce waste volume and life-cycle cost to DOE; and perform tasks in a safe, environmentally compliant manner.

A contract for treatment services was awarded to British Nuclear Fuels Limited, Inc. in December 1996. They completed construction of the facility in December 2002, fulfilling a Settlement Agreement milestone. The project is slated to treat or repackage and ship starting in 2003.

High-Level Waste and Facilities Disposition

In 1953, reprocessing of spent nuclear fuel began at the INTEC, resulting in the generation of high-level waste, including radioactive liquid waste and sodium-bearing liquid waste. Those wastes were placed into interim storage in underground tanks at the INTEC Tank Farm. Treatment of those wastes began in 1963 through a process called calcining. The resultant waste form, known as calcine, was placed in storage in stainless steel bins at the Calcine Solids Storage Facility. Processing of spent nuclear fuel was curtailed in 1992. The INEEL completed calcining of all nonsodium-bearing liquid high-level waste on February 20, 1998, four months ahead of the June 30, 1998 Idaho Settlement Agreement milestone. Calcining of sodium-bearing liquid waste began immediately following completion of nonsodium liquid waste treatment, more than three years ahead of the Settlement Agreement milestone. DOE plans to process sodium-bearing waste into solid forms suitable for permanent disposal in a manner consistent with the Idaho High-Level Waste Advanced Disposition Final Environmental Impact Statement published September 2002 (DOE/EIS 0287). DOE plans on processing this waste on a schedule that meets the required date of 2012.

The calciner was placed on standby in 2000 while DOE determines whether to upgrade and permit the facility to current standards or develop a new method of treating the remaining stored liquid high-level waste. Treatment alternatives for the remaining liquid and calcined wastes were evaluated in the Idaho High-Level Waste and Facilities Disposition Environmental Impact Statement (see Chapter 2, National Environmental Policy Act). The remaining 3.7 million L (1 million gal) of sodium-bearing liquid waste is stored in 1.14-million L (300,000-gal) underground tanks in the Tank Farm and the 4400 m³of mixed high-level waste calcine in bin sets. As of 2002, six of these tanks have been emptied and one of the tanks has been cleaned to State-approved RCRA standards.

Low-Level Radioactive Waste

Significant accomplishments were achieved during 2002 in the disposal of low-level waste stored and generated at the INEEL. Activities at the RWMC SDA were highlighted by the disposal of over 3988 m³(5216 yd³) of legacy and newly generated low-level waste.

Transuranic Waste

The TRU Program accomplished a significant goal in 2002. The INEEL shipped 2075 m³(2714 yd³) of TRU waste to the WIPP in Carlsbad, New Mexico. When combined with 2001 TRU waste shipments, this met the commitment to ship 3100 m³(4055 yd³) of TRU waste to WIPP two months ahead of the December 31, 2002, Settlement Agreement deadline. Approximately 60 percent of DOE's current inventory of contact-handled TRU waste is at the RWMC.

Waste Minimization/Pollution Prevention

The mission of the INEEL Pollution Prevention Program is to reduce the generation of wastes and pollutants by implementing cost-effective pollution prevention and waste minimization techniques, practices, and policies. Pollution prevention and waste minimization also required by various federal statutes, including but not limited to, the Pollution Prevention Act; RCRA; Executive Order 12856; and Executive Order 12873 (Federal Acquisition, Recycling, and Waste Prevention).

It is the policy of the INEEL to incorporate pollution prevention and waste minimization into every activity. Pollution prevention is one of the key underpinnings of the INEEL Environmental Management System (see Section 3.6). It functions as an important preventive mechanism because generating less waste reduces waste management costs, compliance vulnerabilities, and the potential for releases to the environment. The INEEL is promoting the inclusion of pollution prevention into all planning activities as well as the concept that pollution prevention is integral to mission accomplishment.

In 2002, the INEEL reported 38 pollution prevention projects, which resulted in a waste reduction of 13,906 metric tons (34,306 tons) and decreased the cost of operations by more than $9 million. Noteworthy pollution prevention accomplishments in 2002 include:

Over 90,720 kg (200,000 lb) of radioactively contaminated lead from dismantled casks and shielding was fabricated into lead bricks and reused/recycled by the Idaho State University Accelerator Center, eliminating the need for waste processing and disposal as well as avoiding purchase of new lead bricks.

The INEEL Excess Warehouse promoted surplus sales to the public for a variety of items including desks, chairs, used tires, scrap metal, and computer components, resulting in avoided waste disposal costs of $5,472,772. In addition to the cost savings, $294,284 in sales receipts will help to fund Warehouse operating expenses.

3.6 Environmental Management System

DOE-ID and the INEEL M&O contractor continued to make progress on the effort initiated in 1997 to develop and implement an INEEL-wide Environmental Management System (EMS). The EMS will meet the requirements of International Standards Organization (ISO) 14001, an international voluntary standard for environmental management systems. This standard is being vigorously embraced worldwide and within the DOE complex.

An EMS provides an underlying structure to make the management of environmental activities more systematic and predictable. The EMS focuses on three core concepts: pollution prevention, environmental compliance, and continuous improvement. The primary system components are (1) environmental policy, (2) planning, (3) implementation and operation, (4) checking and corrective action, and (5) management review. DOE-ID is pursuing an EMS enhancement development initiative for the Idaho workforce, and the M&O contractor is working on a parallel effort for the INEEL.

An audit and onsite readiness review conducted in 2001 by an independent ISO 14001 auditor concluded that INEEL was ready for a formal registration audit. A registration audit was conducted May 6-10, 2002, by a third-party registrar. There were no nonconformances identified during the audit and the lead auditor recommended ISO 14001 registration for INEEL facilities, which was received in June 2002. A semi-annual ISO 14001 surveillance conducted in November 2002, supporting maintenance of the registration, found no nonconformances with the ISO standard and highlighted the high degree of professionalism, environmental awareness, and ownership shown by INEEL personnel.

3.7 Other Major Environmental Issues and Activities

Decontamination, Decommissioning, and Demolition Activities

Decontamination, decommissioning, and demolition activities at the INEEL are primarily concerned with the safe and compliant decontamination and decommissioning of inactive facilities. These facilities fall under two broad categories: (1) structures potentially suitable for reuse and (2) structures not suitable for reuse. In the last four years more than 100 buildings have been demolished. Specific projects at various facilities are described below. In 2002, 43 buildings across the INEEL were closed, saving about $2.8 million in maintenance and operating costs.

Test Area North -The Maintenance Building (TAN-615) was decommissioned and decontaminated in 2002. Actions included removing radiologically contaminated hot spots and demolition and final grading of concrete flooring, sump, footings, and the building footprint. TAN-615 was a 390-m²(4200-ft²) steel-framed building constructed in 1956 that housed general maintenance shops.

Power Burst Facility/Waste Reduction Operations Complex -Buildings housing equipment associated with WERF were decontaminated as part of a RCRA Closure in 2002. The WERF incinerator and all auxiliary systems were removed and will be disposed at an offsite facility. The WERF sizing and compaction building was decontaminated and demolished in 2002. The entire closure process will be completed by 2004.

Central Facilities Area -CFA Building 617 was demolished in 2002. The building was over 1022 m³(11,000 ft²) and housed laundry facilities.

Spent Nuclear Fuel

Spent nuclear fuel (SNF) is defined as fuel that has been withdrawn from a nuclear reactor following irradiation and the constituent elements have not been separated. Upon removal, SNF contains some unused enriched uranium and radioactive fission products. Because of its radioactivity (primarily from gamma rays), it must propertly shielded. A large amount of DOE's spent nuclear fuel is from national defense and other programmatic missions. Most of the fuel stored at the INEEL is at the INTEC.

For several years, spent nuclear fuel was reprocessed so recovered fissile material could be reused. However, the need for fuel-grade uranium and plutonium decreased. A 1992 decision to stop reprocessing left a large quantity of spent nuclear fuel in storage.

DOE's spent nuclear fuel is stored in both wet and dry storage. Dry storage is preferred because it reduces concerns about corrosion and is less expensive to monitor. An effort is underway to put spent nuclear fuel in temporary dry storage so that it can be quickly readied for transport once a repository is completed. The INEEL's goal is to begin shipping spent nuclear fuel to a national repository by September 30, 2015. The Idaho Settlement Agreement, and a similar agreement with the state of Colorado, requires that all spent nuclear fuel must be out of Idaho by January 1, 2035.

Spent nuclear fuel transfers and storage facilities are described below.

Fluorinel Dissolution Process and Fuel Storage Facility -This INTEC facility CPP-666, also called FAST, is divided into two parts: a spent fuel storage area and the Fluorinel Dissolution Facility (FDF). This facility went operational in 1983. The storage area consists of six storage pools where spent nuclear fuel is stored under about 11 million L (3 million gal) of water, which provides protective shielding and cooling. Fuel formerly managed in the three storage pools at CPP-603, has been transferred to the newer underwater storage pools at FAST or to dry storage. Eventually, all spent nuclear fuel will be removed from underwater storage pools and placed in a dry storage system in preparation for shipment to a repository. The FDF includes a hot cell with 1.8-m (6-ft) thick concrete walls, where spent nuclear fuel was reprocessed by dissolving it in an acid solution, then chemically separating the uranium or plutonium from the waste products. The FDF was shut down after reprocessing ended in 1992.

Irradiated Fuel Storage Facility -The Irradiated Fuel Storage Facility (IFSF), the dry side of the Wet & Dry Fuel Storage Facility (CPP-603), provides dry storage for spent nuclear fuel. The original facility (the wet side - basins) went operational in 1953. The IFSF was added later and went operational in 1973. The facility has 636 storage positions and is over half full. The majority of the spent nuclear fuel stored at the IFSF came from the Fort St. Vrain commercial reactor in Colorado. These shipments stopped in 1991. Current and projected receipts at the IFSF include foreign and domestic research reactor fuel and spent nuclear fuel from two INEEL facilities: the Materials Test Reactor (MTR) and the PBF.

More than 98 cans of spent nuclear fuel in wet storage in the MTR canal and an additional 7 cans of spent nuclear fuel from ATR-603 Plug Storage Cells were transferred to interim dry storage at the IFSF in 2002.

TAN Hot Shop/Manufacturing & Assembly Facility -TAN Hot Shop/Manufacturing & Assembly Facility, TAN-607, contains a hot shop (for handling spent nuclear fuel), and a spent fuel storage basin. TAN-607 went operational in 1955. Loss-of-Fluid Test, commercial, and test reactor SNF (3.6891 MTHM) was transferred from wet storage in the basin, dried, placed within three casks, and the casks relocated to the storage pad, TAN-791, in 2002. In addition, 0.0385 MTHM of epoxied spent nuclear fuel from the TAN-607 Hot Shop was transferred to TAN-791.

TMI-2 Independent Spent Fuel Storage Installation -The Independent Spent Fuel Storage Installation (ISFSI) CPP-1774 is a new NRC-licensed dry storage area for spent fuel and debris from the Three-Mile Island reactor accident. Fuel and debris was transferred to the TAN for examination, study, and storage following the accident. After examination the spent fuel and debris were transferred to the ISFSI. The ISFSI provides safe, environmentally secure, aboveground storage for the spent fuel and debris, which is kept in metal casks inside concrete vaults.

Power Burst Facility -The PBF, built in 1970, supported DOE and NRC studies of reactor fuel during normal and off-normal operating conditions. The PBF operated as a one-of-a-kind facility, with the ability to subject fuel samples to extraordinary power surges in milliseconds, causing the fuel to fail in an isolated, contained system. The NRC then used that information in developing safe operating limits for the commercial nuclear industry. In 1985, the PBF reactor was placed on standby status. In 1998, the PBF was placed in shutdown status and is currently preparing for defueling. PBF fuels kept in the PBF Pool (PBF-620) are being prepared for transfer to the IFSF in 2003.

Peach Bottom Fuel Storage Facility -The Peach Bottom Fuel Storage Facility, CPP-749 consists of below ground vaults for the dry storage of spent nuclear fuel. Located on approximately 5 paved acres, this facility houses 193 underground vaults of various sizes for the dry storage of nuclear fuel rods. The vaults are generally constructed of carbon steel tubes with some of them containing concrete plugs. All of the tubes are totally below grade and are accessed from the top using equipment specifically designed for this use. This facility stores Peach Bottom fuel as well as other unirradiated fuels.

Fort Saint Vrain Independent Spent Fuel Storage Installation -The Department manages this off site NRC-licensed dry storage facility containing about 2/3 of the spent nuclear fuel generated by the Ft. St. Vrain reactor in Ft. St. Vrain, Colorado.

Sagebrush Steppe Ecosystem Reserve

In 1999, DOE signed a Memorandum of Understanding with the Bureau of Land Management, the U.S. Fish and Wildlife Service, and the Idaho Fish and Game Department to establish the INEEL Sagebrush Steppe Ecosystem Reserve. The reserve includes approximately 30,000 ha (74,000 acres) of high-desert land within the INEEL boundaries that are used by 270 animal species and 400 plant species and compose one of the last undisturbed sagebrush steppe ecosystems in the United States. It is part of a complex wide effort by DOE to identify, protect, and conserve environmentally significant parcels of land in partnership with federal and state agencies.

The agreement charters the Bureau of Land Management with the development of a management plan that will provide management direction to DOE for protection of this unique habitat for scientific study and the benefit of future generations. The Bureau of Land Management issued the draft management plan for public review and comment in September 2002 and held several public meetings to discuss the draft plan. Among the issues discussed in the plan are wildfire and wildfire suppression, livestock grazing, road management, and protection of cultural and tribal resources. The Bureau of Land Management is also working on a National Environmental Policy Act environmental assessment for the reserve that will be released in 2003.

Water Integration Project

DOE-ID established the Water Integration Project in January 2002 to better coordinate operations, scientific research, and subsurface monitoring programs at the INEEL. The ultimate goal of the program is to reduce risk to the public, workers, and the environment. The project objectives are to

Enhance scientific understanding of surface water, groundwater, and contaminant movement at the INEEL;

Strengthen and better coordinate groundwater and vadose zone monitoring programs;

Improve the technical basis for making cleanup decisions to ensure that the Snake River Plain Aquifer is protected for the long term;

Identify and fill gaps in understanding of contaminant and water movement;

Establish an expert peer review panel to review the project's technical products;

Emphasize clarity, consistency, and accessibility in information management; and

Engage the public and stakeholder organizations in meaningful dialogue throughout the life of the project.

For more information, access the Water Integration Project website at http://www.inel.gov/environment/water/.

Environmental Oversight and Monitoring Agreement

The Environmental Oversight and Monitoring Agreement between DOE-ID, DOE Naval Reactors, Idaho Branch Office, and the state of Idaho maintains the State's program of independent oversight and monitoring established under the first agreement creating the state of Idaho INEEL Oversight Program. The main objectives as established under the current five year agreement are to

Assess the potential impacts of present and future DOE activities in Idaho;

Assure citizens of Idaho that all present and future DOE activities in Idaho are protective of the health and safety of Idahoans and the environment; and

Communicate the findings to the citizens of Idaho in a manner that provides them the opportunity to evaluate potential impacts of present and future DOE activities in Idaho.

The INEEL Oversight Program's main activities include environmental surveillance, radiological emergency planning and response, impact assessment, and public information. More information can be found on the Oversight Program website at http://www.oversight.state.id.us/.

Citizens Advisory Board

The INEEL Citizens Advisory Board, one of the Environmental Management Site-Specific Advisory Boards, was formed in March 1994. Its charter is to provide input and recommendations on DOE Environmental Management's strategic decisions that impact future use, risk management, economic development, and budget prioritization activities.

The Citizens Advisory Board has produced 101 recommendations during its tenure. In 2002, the Board made recommendations on the following 14 topics:

Draft DOE Long-Term Stewardship Strategic Plan;
Implementation of the DOE Long-Term Stewardship Strategic Plan;
Implementation of the DOE Long-Term Stewardship Plan at the INEEL;
Community Forum to Define the Future of the INEEL;
Proposed Plan for Operable Unit 10-04; Waste Area Group 6 and 10;
INEEL Long-Term Stewardship Vision, Mission, Goals, and Objectives;
Public Involvement to Support Priority Setting for the Expedited Cleanup Agreement at the INEEL;
Science and Technology Budget for Fiscal Year 2003;
Draft DOE-ID Strategic Plan;
Stakeholder Involvement Plan for the INEEL Water Integration Project;
Draft Environmental Management Performance Management Plan for Accelerating Cleanup of the INEEL;
Draft INEEL Wildland Fire Management Environmental Assessment;
Site Transition Framework for Long-Term Stewardship; and
Final Idaho High-Level Waste and Facilities Disposition Environmental Impact Statement.

REFERENCES

63 FR 189, 1998, “Final Modification of the National Pollutant Discharge Elimination System Storm Water Multi-Sector General Permit for Industrial Activities,” Federal Register, U.S. Environmental Protection Agency, September 30, p. 52430.

DOE Order 5400.1, 1993 “General Environmental Protection,” U.S. Department of Energy, January.

DOE-ID, 1991, Idaho National Engineering Laboratory Historical Dose Evaluation, Appendix E, Environmental Surveillance, DOE/ID-12119, Vol. 2, August.

DOE-ID, 1993a, Idaho National Engineering Laboratory Groundwater Monitoring Plan, DOE/ID-10441.

DOE-ID 1993b, Idaho National Engineering Laboratory Groundwater Protection Management Plan, DOE/ID-10274, March.

Twining, B.V., Rattray, G., and Campbell, L.J., 2003, Radiochemical and Chemical Constituents in Water from Selected Wells and Springs from the Southern Boundary of the Idaho National Engineering and Environmental Laboratory to the Hagarman Area, Idaho, 2001, U.S. Geological Survey Open-File Report 01-168, DOE/ID-22185, 32 p.