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One potential pathway for exposure (primarily to workers) to contaminants released from the Idaho National Engineering and Environmental Laboratory (INEEL) is through the water pathway (surface water, drinking water, and groundwater). The Management and Operating contractor monitors liquid effluents, drinking water, groundwater, and storm water runoff at the INEEL to comply with applicable laws and regulations, U.S. Department of Energy (DOE) orders, and other requirements (e.g., Wastewater Land Application Permit [WLAP] requirements). Argonne National Laboratory-West and the Naval Reactors Facility conduct their own WLAP equivalent and drinking water monitoring.
During 2004, liquid effluent and groundwater monitoring was conducted in support of WLAP requirements for INEEL facilities that generate liquid waste streams covered under WLAP rules. The WLAP rules generally require compliance with the state of Idaho groundwater quality primary and secondary constituent standards in specified groundwater monitoring wells. The permits specify annual discharge volume, application rates, and effluent quality limits. As required, an annual report was prepared and submitted to the Idaho Department of Environmental Quality. Additional parameters are also monitored in the effluent released in support of surveillance activities.
Results of most wastewater and groundwater samples taken in support of WLAPs were below applicable limits in 2004. Several metals detected in October 2004 samples taken from the Idaho Nuclear Technology and Engineering Center (INTEC) New Percolation Ponds perched water compliance wells ICPP-MON-V-200 and ICPP-MON-V-212 were above their respective state of Idaho groundwater secondary constituent standards and therefore, above the WLAP limits. Concentrations of aluminum, iron, and manganese in October 2004 samples collected from well ICPP-MON-V-200 and iron in the October 2004 sample collected from well ICPP-MON-V-212 were above the permit limits. For well ICPP-MON-V-212, this was the first time that a permit limit was exceeded. An evaluation was performed to determine the source of aluminum, iron, and manganese in INTEC New Percolation Ponds wells ICPP-MON-A-166, ICPP-MON-A-167, and ICPP-MON-V-200. The evaluation indicated that the majority of the metals found in these wells were from suspended solids. The evaluation further indicated that the likely cause of the suspended solids was from washed-in interbed material either near the well completion zones or from sediment in-filled fractures in the basalt. Sediment infilling is a common occurrence in fractures, rubble zones, and void spaces in the Snake River Plain basalt flows (Hull, Wright, and Street 2004).
During the 2004 permit year, WLAP-required groundwater samples were collected in April and October from the INTEC STP monitoring wells. As in previous years, the concentrations of chloride and nitrate as nitrogen in USGS-052 were elevated compared to USGS-121 (an upgradient background well). Although the chloride and nitrate concentrations in samples collected from USGS-052 were higher than those found in the background well, all parameters in well USGS-052 were in compliance with permit limits during 2004.
The only TAN/TSF STP monitoring well that had constituents that were above permit limits was compliance well TAN-10A. The concentrations of iron, manganese, and total dissolved solids (TDS) in well TAN-10A exceeded the associated permit limits. Further evaluation is needed to determine what impacts the effluent, condition of the well, and past disposal practices are having on the constituent concentration in samples collected from well TAN-10A.
Monthly total nitrogen in the effluent from the INTEC STP exceeded the monthly average permit limit of 20 mg/L during February 2004, June 2004, and August 2004. With the termination of the INTEC STP WLAP (LA-000115-02) on December 2, 2004, the wastewater will no longer be discharged to the INTEC STP rapid infiltration (RI) trenches, and the combined effluent being discharged to the INTEC New Percolation Ponds is not expected to have the elevated concentrations associated with the INTEC STP effluent.
The December 2004 monthly total suspended solids (TSS) concentration in the TAN/TSF STP effluent exceeded the permit limit of 100 mg/L. Soil has washed into the manholes of the TAN/TSF collection system and has deposited in the sump where the effluent samples are collected. Removal of the soil is planned.
The M&O contractor Drinking Water Program monitors 10 onsite water systems, which include 17 wells. During 2004, 435 routine samples and 55 quality control samples were collected and analyzed from the INEEL. No U.S. Environmental Protection Agency (EPA) health-based drinking water or DOE regulatory limits were exceeded in 2004. In the Radioactive Waste Management Complex public water system, carbon tetrachloride remained below the EPA established maximum contaminant level (MCL) of 5 µg/L. The MCL applies only at the compliance point, which is the distribution system. The annual average for the compliance point of the distribution system was 3.35 µg/L. The annual average for the production well of 4.88 µg/L was also below the MCL. Trichloroethylene concentrations in samples from the Test Area North drinking water Well #2 during 2004 also remained below the MCL.
Elevated levels of tritium continue to be measured in the groundwater at the INEEL. This radionuclide has not been detected off the INEEL since the mid-1980s. A maximum effective dose equivalent of 0.47 mrem/yr (4.7 µSv/yr), less than the four mrem/yr EPA standard for public drinking water systems, was calculated for workers at the Central Facilities Area at the INEEL in 2004.
As required by the General Permit for storm water discharges from industrial activity, visual examinations were conducted and samples were collected from selected locations. The visual examinations performed in 2004 showed satisfactory implementation of the INEEL Storm Water Pollution Prevention Plan for Industrial Activities (DOE-ID 2002), and no corrective actions were required or performed during the year. An October 27, 2003, letter from the EPA Region 10 to the DOE, Idaho Operations Office (DOE-ID) chief counsel, determined that three sites at the INEEL (RWMC, INTEC, and the north part of the INEEL property near Birch Creek [area around TAN]) do not have a reasonable potential to discharge storm water to waters of the United States (Ryan 2003). As a result, on December 15, 2003, the DOE-ID contract officer directed the M&O contractor Prime Contracts manager to cease compliance activities associated with the Storm Water Pollution Prevention Plan for Industrial Activities (SWPPP-IA), Storm Water Pollution Prevention Plan for Construction Activities (SWPPP-CA), and Spill Prevention Control and Countermeasures (SPCC) Programs at these three sites (Bauer 2003). The DOE-ID further directed the M&O contractor to:
The storm water corridor technical analyses will be completed in early 2005, and may result in the cessation of compliance activities associated with additional monitoring locations.
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Operations at facilities located on the Idaho National Engineering and Environmental Laboratory (INEEL) release radioactive and nonradioactive constituents into the environment. These releases are in compliance with regulations, and monitoring of these releases ensures protection of the public and environment. This chapter presents results from radiological and nonradiological analyses of liquid effluent, groundwater, drinking water, and storm water samples taken at both onsite and offsite locations. Results from sampling conducted by the Management and Operating (M&O) contractor; Argonne National Laboratory-West (ANL-W), and the Naval Reactors Facility (NRF) are all presented here. Results are compared to the appropriate regulatory limit (e.g., liquid effluent discharge permit limits, U.S. Environmental Protection Agency [EPA] health-based maximum contaminant levels [MCL] for drinking water, and/or the U.S. Department of Energy [DOE] Derived Concentration Guide [DCG] for ingestion of water).
This chapter begins with a general overview of the organizations responsible for monitoring the various types of water at the INEEL in Section 5.1. Sections 5.2 and 5.3 describe liquid effluent and groundwater monitoring as required by the City of Idaho Falls and Wastewater Land Application Permit (WLAP) and effluent monitoring that is done for surveillance activities only. The INEEL drinking water programs are discussed in Section 5.4. Section 5.5 describes storm water monitoring, while Section 5.6 summarizes onsite waste management water surveillance activities.
The M&O contractor monitors liquid effluents, groundwater, drinking water, and storm water runoff at the INEEL to comply with applicable laws and regulations, DOE orders, and other requirements (e.g., WLAP requirements).
The NRF monitors liquid effluent and drinking water to comply with applicable laws and regulations, proposed WLAP conditions, or as best management practices. Effluent samples were analyzed for radionuclides, inorganic constituents, and purgeable organic compounds, while drinking water parameters are covered by State and Federal regulations.
ANL-W also performs independent monitoring of liquid effluent and drinking water at its facility to comply with applicable laws and regulations, proposed WLAP conditions, or as best management practices. Industrial and sanitary liquid effluent samples are analyzed for gross activity (alpha and beta), tritium, inorganics, and water quality parameters. Drinking water parameters are covered under State and Federal regulations.
The INEEL Oversight Program collects split samples with the M&O and other INEEL contractors of liquid effluents, groundwater, drinking water, and storm water. Results of the Oversight programs monitoring are presented in annual reports prepared by that organization and are not reported here.
Table 5-1 presents the various water-related monitoring activities performed on and around the INEEL.
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The M&O contractor monitors for nonradioactive and radioactive parameters in liquid waste effluent and groundwater. Wastewater is typically discharged to the ground surface and evaporation ponds. Discharges to the ground surface are through infiltration ponds, trenches, or a sprinkler irrigation system at the following areas:
Discharge of wastewater to the land surface is regulated under Idaho WLAP rules (IDAPA 58.01.17). An approved WLAP will normally require monitoring of nonradioactive parameters in the influent waste, effluent waste, and groundwater, as applicable. The liquid effluent and groundwater monitoring programs support WLAP requirements for INEEL facilities that generate liquid waste streams covered under WLAP rules. Table 5-2 lists the five facilities operated by the M&O contractor that require WLAPs and the current permit status of each facility.
The WLAPs generally require compliance with the Idaho groundwater quality primary constituent standards (PCS) and secondary constituent standards (SCS) in specified groundwater monitoring wells (IDAPA 58.01.11). The permits specify annual discharge volume and application rates and effluent quality limits. As required, an annual report is prepared and submitted to the Idaho Department of Environmental Quality (DEQ).
During 2004, the M&O contractor conducted monitoring as required by the permits for each of the first four facilities listed in Table 5-2. The TRA Cold Waste Pond has not been issued a permit; however, quarterly samples for total nitrogen and total suspended solids (TSS) are collected to show compliance with the regulatory effluent limits for rapid infiltration systems. The following subsections present results of wastewater and groundwater monitoring for individual facilities conducted for permit compliance purposes.
Additional parameters are also monitored in the effluent to comply with DOE Order 5400.5 and 450.1 (DOE 1993, DOE 2003) environmental protection objectives. Section 5.3 discusses the results of liquid effluent surveillance monitoring for individual facilities operated by the M&O contractor and those additional facilities monitored by ANL-W (Industrial Waste Ditch and Pond, the ANL-W Sanitary Lagoons), and the NRF (Industrial Waste Ditch).
Description - The City of Idaho Falls is authorized by the Clean Water Act, National Pollutant Discharge Elimination System (NPDES) to set pretreatment standards for nondomestic wastewater discharges to publicly owned treatment works. The DOE - Idaho Operations (DOE-ID) Office and M&O contractor facilities in Idaho Falls are required to comply with the applicable regulations in Chapter 1, Section 8 of the Municipal Code of the City of Idaho Falls.
Industrial Wastewater Acceptance Forms were obtained for facilities that discharge process wastewater through the City of Idaho Falls sewer system. Twelve M&O contractor facilities in Idaho Falls have associated Industrial Wastewater Acceptance Forms for discharges to the city sewer system. The Industrial Wastewater Acceptance Forms for these facilities contain special conditions and compliance schedules, prohibited discharge standards, reporting requirements, monitoring requirements, and effluent concentration limits for specific parameters; however, only the INEEL Research Center has specific monitoring requirements.
Wastewater Monitoring Results - Semiannual monitoring was conducted at the INEEL Research Center in April and October of 2004. Table 5-3 summarizes the 2004 semiannual monitoring results.
Description - The CFA Sewage Treatment Plant (STP) serves all major facilities at CFA. It is southeast of CFA, approximately 671 m (2,200 ft) downgradient of the nearest drinking water well.
A 1,500 L/min (400 gal/min) pump applies wastewater from a 0.2 ha (0.5 acre) lined, polishing pond to approximately 30 ha (74 acres) of desert rangeland through a computerized center pivot irrigation system. The permit limits wastewater application to 25 acre-in./acre/yr from March 15 through November 15, and limits leaching losses to 8 cm/yr (3 in./yr).
WLAP Wastewater Monitoring Results - The permit requires influent and effluent monitoring, as well as soil sampling in the application area (see Chapter 7 for results pertaining to soils). Influent samples were collected monthly from the lift station at CFA (prior to Lagoon No. 1) during 2004. Effluent samples were collected from the pump pit (prior to the pivot irrigation system) starting in June 2004 and continued through October 2004 (the period of irrigation operation for 2004). All samples collected were 24-hr composites, except pH and coliform samples, which were collected as grab samples. Table 5-4 and Table 5-5 summarize the results.
Discharge to the pivot irrigation area averaged less than 647,235 Lpd (171,000 gpd). Application rates ranged from 0.03 to 0.12 acre-in./day during the entire 2004 application period of June 28, 2004, through October 21, 2004.
The total volume of applied wastewater for 2004 was approximately 13.64 MG, which is significantly less than the design hydraulic loading of 40.5 MG. Hydraulic loading peaked in September. Nitrogen loading rates were significantly lower (0.8 lb/acre/yr) than the projected maximum loading rate of 32 lb/acre/yr. As a general rule, nitrogen loading should not exceed the amount necessary for crop utilization plus 50 percent. However, wastewater is applied to rangeland without nitrogen removal via crop harvest. To estimate nitrogen buildup in the soil under this condition, a nitrogen balance was prepared by Cascade Earth Science, Ltd., which estimated it would take 20 to 30 years to reach normal nitrogen agricultural levels in the soil (based on a loading rate of 32 lb/acre/year) (CES 1993). The extremely low 2004 nitrogen loading rate had a negligible effect on nitrogen accumulation.
The 2004 annual total chemical oxygen demand (COD) loading rate at CFA STP (35 lb/acre/year) was substantially less than state guidelines of 50 lb/acre/day (which is equivalent to 18,250 lb/acre/year).
The annual total phosphorus loading rate (0.237 lb/acre/year) was well below the projected maximum loading rate of 4.5 lb/acre/year. The small amount of phosphorus applied was probably removed by sorption reactions in the soil and utilized by vegetation, rather than lost to groundwater.
Removal efficiencies (REs) were calculated to estimate treatment in the lagoons. Average REs were higher than the previous year for all four parameters. Total nitrogen, biochemical oxygen demand (BOD) and TSS achieved the projected efficiency of 80 percent, and COD was below the projected efficiency of 70 percent. During the 2004 permit year, the average REs indicate that treatment in the lagoons was sufficient to produce a good quality effluent for land application. A total of 6.83 acre-in./acre of wastewater was applied over approximately 7.4 acres during the 2004 permit year, which was 3.84 in. more than that applied in 2003. This total, when adjusted for irrigation efficiency and added to the total adjusted precipitation for the permit year, yields 12.37 acre-in./acre, which is well below the permit limit of 25 acre in./acre/year. This resulted in no leaching and, therefore, was well below the permit limit of 7.6 cm (3 in.) per year.
WLAP Groundwater Monitoring Results - The WLAP does not require groundwater monitoring at the CFA STP.
Description - The Percolation Ponds receive only nonhazardous wastewater. Wastewater with the potential to contain hazardous constituents is disposed of in accordance with the applicable Resource Conservation and Recovery Act requirements. Sanitary wastes from restrooms and the INTEC cafeteria are either discharged to the INTEC STP or directed to onsite septic tank systems.
The INTEC New Percolation Ponds were placed into service August 26, 2002, and the INTEC Existing Percolation Ponds were isolated from further use. During normal operations, INTEC generates an average of 1 to 2 MG per day of process wastewater (commonly called service waste) that is discharged to the New Percolation Ponds. The service waste system serves all major facilities at INTEC. This process-related wastewater from INTEC operations consists primarily of steam condensates, noncontact cooling water, reverse osmosis products, water softener and demineralizer regenerate, and boiler blowdown wastewater.
The new pond complex is a rapid infiltration system and is comprised of two ponds excavated into the surficial alluvium and surrounded by bermed alluvial material. Each pond is approximately 93 x 93 m (305 x 305 ft) at the top of the berm and is about 3 m (10 ft) deep. Each pond is designed to accommodate a continuous wastewater discharge rate of approximately 11 million Lpd (three MG per day).
During normal operation, wastewater is discharged to only one pond at a time. Periodically, the pond receiving the wastewater will be alternated to minimize algae growth and maintain good percolation rates. Ponds are routinely inspected, and the water depth is recorded via permanently mounted staff gauges.
The WLAP (LA-000130-03) for the INTEC New Percolation Ponds issued by DEQ was in effect through December 3, 2004. A request for a major permit modification to expand facility operations associated with the INTEC New Percolation Ponds by routing the sanitary wastewater from the INTEC STP (WLAP LA-000115-02) to the INTEC service waste system and discharge the combined effluent to the INTEC New Percolation Ponds was submitted to DEQ in 2003. The new WLAP (LA-000130-04) was issued and became effective on December 2, 2004, when the two wastewaters were combined for discharge to the INTEC New Percolation Ponds.
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WLAP Wastewater Monitoring Results - The WLAP for the New Percolation Ponds requires effluent monitoring, as well as groundwater sampling. A 24-hr flow-proportional composite sample is collected monthly from the sample point in CPP-797 for all parameters except pH, which is taken as a grab sample as required by the permit. Table 5-6 summarizes the effluent results from the NTEC New Percolation Ponds. Table 5-7 shows the effluent results for December 2004 after the two waste streams were combined on December 2, 2004.
The permit for the INTEC New Percolation Ponds WLAP LA-000130-04 (effective as of December 2, 2004) specifies limits for TSS of 100 mg/L and 20 mg/L for total nitrogen. These limits were not exceeded in the December 2004 sample.
Prior to December 2004, the previous WLAP (LA-000130-03) did not specify concentration limits for the effluent to the ponds. However, to aid in monitoring plant efficiency, effluent concentrations were compared to the groundwater quality standards. When comparing the effluent concentrations to the groundwater quality standards as an indicator of plant efficiency, only chloride was above the standards and only during one month of the year (February 2004). However, because there are no permit limits for chloride in the effluent, the chloride concentration during February does not reflect a permit noncompliance. Historically, concentrations of total dissolved solids (TDS), chloride, and sodium have all been high in the service waste effluent and have been considered indicative of a problem with the CPP-606 water treatment system. Evaluations of design options to upgrade the water treatment system were ongoing during the 2004 permit year, and the new permit for the combined effluents (WLAP LA-000130-04) includes a compliance requirement to submit a salt loading corrective action plan and schedule to reduce salt loading to the INTEC New Percolation Ponds.
The flow volumes to the New Percolation Ponds were recorded daily from the flow meter located in CPP-797. Total flow discharged to the New Percolation Ponds in 2004 was approximately 1,647 million L (435.3 MG).
WLAP Groundwater Monitoring Results - To measure potential impacts to groundwater from the New Percolation Ponds, the permit requires that groundwater samples be collected semiannually from six monitoring wells:
The permit requires that samples be collected semiannually during April and October and provides a specified list of parameters to be analyzed for in the groundwater samples. Aquifer wells ICPP-MON-A-165 and ICPP-MON-A-166 and perched water wells ICPP-MON-V-200 and ICPP-MON-V-212 are the permit compliance points. Contaminant concentrations in the aquifer compliance wells are limited by the natural background concentrations in those wells. According to IDAPA 58.01.11.200.03, if the natural background level of a constituent exceeds the standard in this Section (i.e., IDAPA 58.01.11.200.01), the natural background shall be used as the standard. Because there were no natural background levels for the two perched wells listed as compliance points, these wells are limited by the groundwater PCS and SCS in IDAPA 58.01.11.200.01. All permit required samples are collected as unfiltered samples.
Table 5-8 shows the April and October 2004 water table elevations and depth to water table, determined prior to purging and sampling, and the analytical results for all parameters specified by the permit for aquifer wells. Table 5-9 presents similar information for the perched water wells. Samples were collected from wells ICPP-MON-A-165, ICPP-MON-A-166, ICPP-MON-A-167, ICPP-MON-V-200, and ICPP-MON-V-212. Perched water well ICPP-MON-V-191 was dry during both the April and October 2004 sampling events. Well ICPP-MON-V-191 is expected to remain dry until there is sufficient flow in the Big Lost River to recharge the perched water at this well.
The parameter concentrations in the aquifer wells remained below the preoperational natural background concentrations. The majority of the permit-required parameters in the two perched water wells were below their respective PCS or SCS during the 2004 permit year. However, exceedances were reported for three metals (aluminum, iron, and manganese).
Samples collected from perched water well ICPP-MON-V-200 in April 2004 were below the SCSs for aluminum, iron, and manganese in the unfiltered samples, but were well above the SCSs in the October 2004 unfiltered sample (Table 5-9). The concentration of iron in the unfiltered sample taken from well ICPP-MON-V-212 in October 2004 was above the SCS. This was the first time since sampling began for this well that any of these three metals were above the SCS in an unfiltered sample.
Previous sampling events have shown higher than expected concentrations of aluminum, iron, and manganese in wells ICPP-MON-A-167, ICPP-MON-A-166, and ICPP-MON-V-200. A study (Hull, et al. 2004) was performed to determine the source of the aluminum, iron, and manganese in these three wells. The study evaluated the following:
Hull, Wright, and Street (2004) did not specifically address the concentrations of aluminum, iron, and manganese in the effluent as a possible cause of the elevated levels of these metals in the INTEC New Percolation Ponds wells. However, the average effluent concentrations of these metals are significantly lower than the concentrations in the three wells addressed in the study and are below the respective SCSs.
Hull, Wright, and Street (2004) stated that there were significant
concentrations of aluminum, iron, and manganese in the suspended solids from
samples collected from wells
ICPP-MON-A-166, ICPP-MON-A-167, and ICPP-MON-V-200. The study further indicated that if the suspended solids were removed by using a 0.45 µm filter during sample collection, the concentrations of the three metals would be below the SCSs. To date, all filtered sample results from wells ICPP-MON-A-166, ICPP-MON-A-167, and ICPP-MON-V-200 have been below the SCSs for aluminum, iron, and manganese.
The suspended solids were found to consist primarily of quartz and alumino-silicate minerals. The metals found in the sediments are consistent with the abundance of these metals in the earth's crust. It was concluded that the likely cause of the suspended solids was from washed-in interbed material either near the well completion zones or from sediment in-filled fractures in the basalt. Sediment infilling is a common occurrence in fractures, rubble zones, and void spaces in the Snake River Plain basalt flows (Hull et al. 2004).
Just prior to the April 2004 sampling event, wells ICPP-MON-A-166, ICPP-MON-A-167, and ICPP-MON-V-200 were purged for approximately 83 hours at the maximum rate possible for each well. Aluminum, iron, and manganese concentrations were significantly reduced in the April 2004 samples compared to the previous October 2003 sampling event for wells ICPP-MON-A-166 and ICPP-MON-A-167. For the October 2004 sampling event, these wells were purged to three well volumes as required by the permit instead of the extended purge time that was performed in April 2004. The concentrations of these metals in ICPP-MON-A-167 (the upgradient well) and ICPP-MON-V-200 (a perched water well) increased in October 2004 compared to the April 2004 sample results with the extended purge time. Additional purge time will be considered for future sampling events.
Unlike wells ICPP-MON-A-167 and ICPP-MON-V-200, well ICPP-MON-A-166 did not show a significant increase in the metals concentrations between the April and October 2004 sampling events. Hull, Wright, and Street (2004) indicated that there was a potential that the bottom of the well screen in well ICPP-MON-A-166 might have been damaged by a pipe that had accidentally been dropped down the well bore. In addition, the turbidity in the well was not reduced during the extended purging in April 2004. Because of this, a sand/gravel pack was placed in well ICPP-MON-A-166 prior to the October 2004 sampling event. Approximately 0.6 m (2 ft) of silica sand was placed at the bottom of the well followed by a 0.6 m (2 ft)-thick layer of washed pea gravel. The sampling logbook indicates that the water cleared up quickly and remained clear during the October 2004 sampling. Future sampling events will determine whether the sand gravel pack was effective.
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Description - The INTEC Sewage Treatment Plant (STP) was regulated under WLAP LA-000115-02 through December 2, 2004. A major permit modification request was submitted to the DEQ in 2003 to address the inability to maintain effluent toal nitrogen, to eliminate a discharge in the area near INTEC, and to reduce the number of WLAPs. On December 2, 2004, coverage under WLAP LA-000115-02 was terminated when the INTEC STP effluent was combined with the INTEC service waste system wastewater and discharged to the INTEC New Percolation Ponds rather than to the INTEC STP rapid infiltration (RI) trenches. This discharge is now regulated under WLAP LA-000130-04.
The sewage system consists of seven lift stations, which pump the waste into two main lift stations. Both of the two main lift stations contain a sewage grinder that the wastewater passes through before being pumped to the STP. Under WLAP LA-000115-02, the INTEC STP consisted of:
Since the INTEC STP permit (WLAP LA-000130-04) became effective on December 2, 2004, piping to the RI trenches was disconnected, the RI trenches were filled with soil, and the surface aerators were removed.
Automatic flow-proportional composite samplers are located at control stations CPP-769 (influent) and CPP-773 (wastewater from the Sewage Treatment Plant to the rapid infiltration trenches). The composite samplers collect 24 hr flow-proportional samples as required by the permit.
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WLAP Wastewater Monitoring Results - The WLAP LA-000115-02 set effluent (CPP 773, wastewater from the STP to the RI trenches) limits for total nitrogen (total Kjeldahl nitrogen [TKN] + nitrogen, nitrate [NO3] + nitrite [NO2]) and TSS and required that the influent and effluent be sampled and analyzed monthly for these and several other parameters. Influent samples were collected from control station CPP-769, and effluent samples were collected from control station CPP-773. The WLAP (LA-000130-04) for the combined wastewaters discharged to the INTEC New Percolation Ponds still requires samples to be collected from these two locations. However, the new permit does not set limits for total nitrogen or TSS at control stations CPP-769 and CPP 773. The permit-required data are summarized in Table 5-10 and Table 5-11. All samples are collected as 24 hour flow proportional composites, except the monthly total coliform grab samples and the pH grab samples at CPP-773 and CPP-797 under WLAP LA-000130-04 starting December 2, 2004.
Monthly effluent TSS concentrations remained below the limit (effective through December 1, 2004) of 100 mg/L for the reporting period. Monthly total nitrogen exceeded the monthly average limit (effective through December 1, 2004) of 20 mg/L during February 2004, June 2004, and August 2004. With the termination of the INTEC STP WLAP (LA-000115-02) on December 2, 2004, the wastewater will no longer be discharged to the INTEC STP RI trenches, and the combined effluent being discharged to the INTEC New Percolation Ponds is not expected to have the elevated concentrations associated with the INTEC STP effluent.
Total annual effluent flow to the trenches was 41.56 million L (10.98 MG) during 2004. This total includes estimated flow volumes for periods when the flow meter was out of service.
WLAP Groundwater Monitoring Results - To measure potential INTEC Sewage Treatment Plant impacts to groundwater, WLAP LA-000115-02 required collecting groundwater samples semiannually from three monitoring wells:
Sampling was conducted semiannually (April and October) and included a list of specified parameters for analysis. Contaminant concentrations in USGS 052 were limited by the PCS and SCS specified in Idaho regulations (IDAPA 58.01.11, "Ground Water Quality Rule"). All permit required samples are collected as unfiltered samples.
During the 2004 permit year, groundwater samples were collected in April and October. Duplicate samples were collected from USGS-052 in April and October 2004. Table 5-12 shows water table elevations and depth to water table, determined prior to purging and sampling, and analytical results for all parameters required by the permit. Groundwater samples collected from USGS-052 were in compliance with all permit limits during 2004. As in previous years, concentrations of chloride and nitrate as nitrogen in USGS-052 were elevated compared to USGS-121.
Monitoring well ICPP-MON-PW-024 was constructed in the perched water zone approximately 21 m (70 ft) below the surface of the infiltration trenches. It is used as an indicator of treatment efficiency of the soil rather than serving as a point of compliance.
The TDS concentrations in well ICPP-MON-PW-024 typically have been above the SCS of 500 mg/L. For permit year 2004, the TDS concentration in this well increased from 516 mg/L in April to 617 mg/L in October.
Total nitrogen concentrations (comprised of nitrate as nitrogen [NO3-N], nitrite as nitrogen [NO2-N], and TKN) in the perched water closely followed those of the effluent prior to 1997, the difference being that nearly all the total nitrogen in the perched water was comprised of NO3-N, while the effluent was primarily comprised of ammonia as nitrogen (NH3-N). This suggests significant nitrification (a process whereby NH3-N is converted to NO3-N) by the soil but little denitrification to a gas. This can be seen in the April 2004 sample from well ICPP-MON-PW-024 where the NO3-N concentration was above the PCS of 10 mg/L and in the October 2004 sample where the NO3 N was just slightly below the PCS.
Due to quality control issues associated with the April 2004 total and fecal coliform analyses, the data were rejected and the wells were resampled for total and fecal coliform in July 2004. Because a determination was made to reject the April 2004 coliform data, only the July and October 2004 sample results are presented in Table 5-12. Total coliform was detected in both the July and October 2004 samples from ICPP-MON-PW-024. In both instances, the laboratory reported the total coliform results as "too numerous to count" (TNTC). The analytical method allows the laboratory to report total coliform as TNTC when the count exceeds 200 colonies/100 mL. For comparison, the PCS for total coliform is 1 colony/100 mL.
Fecal coliform was also detected in both the July and October 2004 samples collected for well ICPP-MON-PW-024 at 197 colonies/100 mL and 2 colonies/100 mL, respectively. There is not a specific PCS or SCS for fecal coliform. Fecal coliform consists of various genera and species of coliform that are specifically associated with human and animal wastes. The treatment processes at the INTEC STP do not include disinfection of the wastewater. Therefore, the likely source of coliform bacteria in well ICPP-MON-PW-024 was the INTEC STP effluent percolating to the perched water zone in which this well is located.
With the termination of WLAP LA-000115-02, discharge to the RI trenches has been discontinued, and the perched water zone in which ICPP-MON-PW-024 is located is expected to dry up.
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Description - The TAN/TSF Sewage Treatment Facility (TAN 623) was constructed and designed to treat raw wastewater by biologically digesting the majority of the organic waste and other major contaminants, then applying it to the land surface for infiltration and evaporation. The Sewage Treatment Facility consists of
The TAN/TSF Disposal Pond was constructed in 1971; prior to that, treated wastewater was disposed of through an injection well. The TAN/TSF Disposal Pond consists of a primary disposal area and an overflow section, both of which are located within an unlined, fenced 35-acre area. The Overflow Pond is rarely used; it is used only when the water is diverted to it for brief periods of cleanup and maintenance. The TAN/TSF Disposal Pond and Overflow Pond areas are approximately 3623 m2 (39,000 ft2) and 1338 m2 (14,400 ft2), respectively, for a combined area of approximately 4961 m2 (53,400 ft2). In addition to receiving treated sewage wastewater, the TAN/TSF Disposal Pond also receives process wastewater, which enters the facility at the TAN-655 lift station.
The TSF sewage primarily consists of spent water containing wastes from restrooms, sinks, and showers. The sanitary wastewater goes to the TAN 623 Sewage Treatment Facility, and then to the TAN 655 Lift Station, which pumps to the TAN/TSF Disposal Pond.
The process drain system collects wastewater from process drains and building sources originating from various TAN facilities. The process wastewater consists of liquid effluent, such as steam condensate; water softener and demineralizer discharges; cooling water; heating, ventilating, and air conditioning; and air scrubber discharges. The process wastewater is transported directly to the TAN-655 lift station, where it is mixed with sanitary wastewater before being pumped to the TAN/TSF Disposal Pond.
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WLAP Wastewater Monitoring Results - Total effluent to the TAN/TSF Disposal Pond for calendar year 2004 was approximately 45.7 million L (12.07 MG). This total does not include estimated flow volumes for two short periods when the flow meter was out of service. Using hirstorical flow data for these periods would increase the annual total by less than 10 percent.
The permit for the TAN/TSF Sewage Treatment Facility also sets concentration limits for total suspended solids and total nitrogen measured in the effluent to the TAN/TSF Disposal Pond and requires that the effluent be sampled and analyzed monthly for several parameters. During 2004, 24 hr composite samples (except fecal and total coliform, which were grab samples) were collected monthly from the TAN-655 lift station effluent.
Table 5-13 summarizes the effluent monitoring results for calendar year 2004. Monthly concentrations of TSS were below the permit limit (100 mg/L) with the exception of the December 2004 sample that had a concentration of 134 mg/L. Beginning with the October 2004 sample (89.8 mg/L), TSS in the effluent samples have shown a significant increase. Prior to October 2004, the previous highest concentration in 2004 was in the January sample at 25 mg/L. It is believed that sediment has washed into the manholes of the TAN/TSF collection system and deposited in the sump where the effluent samples are collected. Removal of the sediment from these locations is planned.
All monthly total nitrogen (TKN + nitrogen, nitrite+nitrate) concentrations
were below the permit limit of 20 mg/L, with the maximum monthly concentration
of 19.4 mg/L reported in October 2004.
WLAP Groundwater Monitoring Results - To measure potential TAN/TSF Disposal Pond impacts to groundwater, the WLAP for the TAN/TSF Sewage Treatment Facility requires collecting groundwater samples semiannually from four monitoring wells:
Sampling must be conducted semiannually and includes several specified parameters for analysis. Contaminant concentrations in TAN-10A, TAN-13A, and TANT-MON-A-002 are limited by the permit to the PCS and SCS levels in IDAPA 58.01.11, "Ground Water Quality Rule." All permit required samples are collected as unfiltered samples.
During the 2004 permit year, groundwater samples were collected in April and October. Due to quality control issues associated with the April 2004 total and fecal coliform analyses, the April results were rejected, and the wells were resampled for total and fecal coliform in July 2004. Table 5-14 shows water table elevations and depth to water table, determined prior to purging and sampling, and analytical results for all parameters specified by the permit.
Iron concentrations exceeded the SCS of 0.3 mg/L in well TAN-10A in April and October 2004. Iron concentrations in additional filtered samples collected in April and October 2004 from well TAN 10A also exceeded the SCS. Elevated iron concentrations historically have been detected in the TAN WLAP monitoring wells.
Video log information gathered in 2001 on well TAN-10A showed that the carbon steel well casing appeared corroded most of the way to the water table, slime on the well casing below the water table, a partially plugged screen, and approximately a foot of sludge at the bottom of the well. The iron concentrations in well TAN-10A increased after the maintenance was performed in 2001 that replaced the galvanized riser pipe. The iron concentrations in well TAN-10A were above the SCS (0.3 mg/L) in both April 2003 (0.433 mg/L) and October 2003 (1.07 mg/L), but were lower then those in October 2002 (3.02 mg/L and 3.22 mg/L, duplicate). The iron results from April 2004 (1.05 mg/L) and October 2004 (0.872 mg/L) showed similar concentrations to October 2003 and were also above the iron SCS. The residual effects relating to the replacement of the galvanized riser pipe appear to have caused the temporary increase in the iron concentration in October 2002.
The majority of the iron in well TAN-10A appears to be in solution. Table 5-14 shows that the filtered (0.45 µm filter) iron concentrations in this well are similar to the concentrations in the unfiltered samples. It is unclear what impact the concentration of iron in the effluent is having on the iron concentrations in well TAN-10A. For 2004, iron concentrations in 8 of the 12 effluent samples were at or above the SCS of 0.3 mg/L. However, the effluent samples are all collected as unfiltered samples. Therefore, it is unknown whether the iron in the effluent is dissolved in solution. Further evaluation is needed to determine the impacts from the effluent, condition of the well, past disposal practices, and remediation activities are having on the iron concentration in samples collected from well TAN-10A.
For well TAN-10A, manganese was above the SCS of 0.05 mg/L in October 2004. The October 2004 manganese concentration was significantly higher than in April 2004 (Table 5-14) and in both April and October 2003. This is the first time since the original permit was issued that the manganese concentration in this well exceeded the groundwater quality standard, and no cause for the exceedance was identified. Manganese in well TAN-10A will continue to be monitored semiannually, and future groundwater quality standard exceedances will be investigated.
Well TAN-10A continues to have intermittent problems meeting the TDS SCS of 500 mg/L. The April 2004 TDS concentration in well TAN-10A was below the SCS, but the October 2004 concentration (501 mg/L) slightly exceeded the SCS. The condition of the well casing may be contributing to the TDS concentrations in this well. In addition, the TDS in the effluent may be impacting the concentrations in this well. TDS concentrations in th effluent have fluctuated over time, and have occasionally exceeded 500 mg/L.
Total and fecal coliform samples were collected in April and October 2004 as required by the TAN/TSF Sewage Treatment Facility WLAP. However, as stated earlier, due to quality control issues associated with the April 2004 total and fecal coliform analyses, the data were rejected, and the wells were resampled for total and fecal coliform in July 2004. Analytical results (Table 5-14) show that both total and fecal coliform were absent in all samples and wells during the 2004 permit year.
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Description - The TRA Cold Waste Pond was constructed in 1982. The majority of wastewater received by the Cold Waste Pond is secondary cooling water from the Advanced Test Reactor when it is in operation. Chemicals used in the cooling water are primarily commercial corrosion inhibitors and sulfuric acid to control pH. Other wastewater discharges to the Cold Waste Pond are nonhazardous and nonradioactive and include, but are not limited to: maintenance cleaning waste, floor drains, and yard drains.
The cold waste effluents collect at the cold waste well sump and sampling station (TRA 764) before being pumped to the Cold Waste Pond. The cooling tower system has a radiation monitor with an alarm that prevents accidental discharges of radiologically contaminated cooling water.
WLAP Wastewater Monitoring Results - A letter from the Idaho DEQ issued in 2001, authorized the continued operation of the Cold Waste Pond under the terms and conditions of the WLAP regulations (Johnston 2001). As a result, total nitrogen (TKN + nitrogen, nitrite + nitrate) and total suspended solids analyses were added in August 2001 to the list of parameters analyzed quarterly at the Cold Waste Pond. These are the only parameters required for compliance. Other parameters are sampled for surveillance purposes, which are discussed in Section 5.3.
Automated samplers are used to collect quarterly 24-hour time-proportional composite samples from TRA-764. Total suspended solids and total nitrogen results are summarized in Table 5-15. For 2004, all total suspended solids results were below the laboratory's minimum detection level of 4 mg/L. The regulatory limit for TSS is 100 mg/L. The maximum total nitrogen concentration during 2004 was 2.55 mg/L, which was significantly less than the regulatory limit of 20 mg/L.
WLAP Groundwater Monitoring Results - Currently, there are no groundwater monitoring requirements associated with the TRA Cold Waste Pond. However, groundwater monitoring is expected to be required when a permit is issued.
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As stated in Section 5.2, additional radiological and nonradiological parameters specified in the Idaho groundwater quality standards also are monitored. The results of this additional monitoring are discussed by individual facility in the following sections. This additional monitoring is performed to comply with DOE Order 450.1 and 5400.5 environmental protection objectives.
During 2004, the Industrial Waste Pond, Industrial Waste Ditch, and Secondary Sanitary Lagoon at ANL-W were monitored monthly for iron, sodium, chloride, fluoride, sulfate, pH, conductivity, total dissolved solids, turbidity, biological oxygen demand, gross alpha, gross beta, gamma spectrometry, and tritium. Additionally, the Secondary Sanitary Lagoon was also monitored monthly for total coliform. All chemical parameters for both ponds and the waste ditch were well below applicable limits. (Table 5-16)
Both the influent and effluent to the CFA Sewage Treatment Plant are monitored according to the WLAP issued for the plant. Table 5-17 summarizes the additional monitoring conducted during 2004 at the CFA Sewage Treatment Plant and shows those parameters with at least one detected result during the year. Additional monitoring is performed quarterly from the floor drains and vehicle maintenance areas of the Transportation Complex at CFA 696. During 2004, most additional parameters were within historical concentration levels.
Wastewater Land Application Permits are in effect for the INTEC Sewage Treatment Plant and the INTEC New Percolation Ponds. Table 5-18 summarizes the additional monitoring conducted during 2004 at INTEC and shows those parameters with at least one detected result during the year.
During 2004, most additional parameters were within historical concentration levels. No parameters were analyzed for at the INTEC New Percolation Ponds beyond those required by the permit.
The effluent to the TAN/TSF Disposal Pond receives a combination of process water from various TAN facilities and treated sewage waste. Additional monitoring for surveillance purposes is conducted monthly for metal parameters and quarterly for radiological parameters [with the exception of strontium-89 [89Sr], strontium-90 [90Sr], iodine-129 [129I], and tritium, which are monitored annually]. Table 5-19 summarizes the results of this additional monitoring for those parameters with at least one detected result. During 2004, the concentrations of most additional parameters were within historical concentration levels.
Since strontium-90 exceeded the drinking water Maximum Contaminant Levels (MCLs) in January 2004, additional samples for strontium-90 were collected throughout the year, and none of the additional samples exceeded MCLs. It was subsequently determined that the presence of strontium-90 in the TAN-655 effluent is incidental to past processes, and no further evaluation or analyses are necessary (Hutten 2004)
The effluent to the Cold Waste Pond receives a combination of process water from various TRA facilities. Additional monitoring for surveillance purposes is conducted quarterly for metal parameters and for radiological parameters. Table 5-20 summarizes the results of this additional monitoring for those parameters with at least one detected result. During 2004, the concentrations of the additional parameters were within historical levels. The largest volume of wastewater received by the TRA Cold Waste Pond is secondary cooling water from the Advanced Test Reactor when it is in operation. During 2004, concentrations of sulfate and TDS were elevated in samples collected during reactor operation. These differences are due to the normal raw water hardness, as well as corrosion inhibitors and sulfuric acid added to control the cooling water pH. Concentrations of sulfate and TDS exceeded the risk-based release levels specific for the TRA Cold Waste Pond during reactor operation but not during reactor outages. The annual average was below the risk-based release limit, which is the concentration predicted to degrade groundwater quality to above drinking water standards.
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In 1988, a centralized drinking water program was established. Each contractor (BBWI, ANL-W, and NRF) participates in the INEEL Drinking Water Program. However, during 2004, each contractor (BBWI, BNFL, NRF, ANL-W) administered their own drinking water program.
The Drinking Water Program was established to monitor drinking water wells, which are multiple use wells for industrial use, fire safety, and drinking water. According to the "Idaho Regulations for Public Drinking Water Systems" (IDAPA 58.01.08), INEEL drinking water systems are classified as either nontransient or transient, noncommunity water systems. The M&O contractor transient, noncommunity water systems are at the Experimental Breeder Reactor No. 1 (EBR-I), the Gun Range, and the Main Gate. The rest of the M&O contractor water systems are classified as nontransient, noncommunity water systems, which have more stringent requirements than transient, noncommunity water systems.
The Drinking Water Program monitors drinking water to ensure it is safe for consumption and to demonstrate that it meets federal and state regulations (that MCLs are not exceeded). The federal Safe Drinking Water Act also establishes requirements for the Drinking Water Program.
Because groundwater supplies the drinking water at the INEEL, information on groundwater quality was used to help develop the Drinking Water Program. The U.S. Geological Survey (USGS) and the various contractors monitor and characterize groundwater quality at the INEEL. Three groundwater contaminants have impacted M&O contractor drinking water systems: tritium at CFA, carbon tetrachloride at the Radioactive Waste Management Complex (RWMC), and trichloroethylene at TAN/TSF.
As required by the state of Idaho, the Drinking Water Program uses EPA-approved (or equivalent) analytical methods to analyze drinking water in compliance with current editions of IDAPA 58.01.08 and Title 40 Code of Federal Regulations (CFR) parts 141-143. State regulations also require the use of laboratories that are certified by the state of Idaho or certified by another state whose certification is recognized by the state of Idaho for their drinking water analyses. The DEQ oversees the certification program and maintains a listing of approved laboratories.
Currently, the M&O contractor Drinking Water Program monitors 10 onsite water systems, which include 17 wells. Drinking water parameters are regulated by the state of Idaho under authority of the Safe Drinking Water Act. Parameters with primary MCLs must be monitored at least once during every three-year compliance period. Parameters with secondary MCLs are monitored every three years based on a recommendation by the EPA. The three year compliance periods for the M&O contractor Drinking Water Program are 2002 to 2004, 2005 to 2007, and so on. Many parameters require more frequent sampling during an initial period to establish a baseline, and subsequent monitoring frequency is determined from the baseline.
Because of known contaminants, the M&O contractor Drinking Water Program monitors certain parameters more frequently than required. For example, the program monitors for bacteriological analyses more frequently because of historical problems with bacteriological contamination. These past detections were probably caused by biofilm on older water lines and stagnant water. In 2004, no maximum contaminant level was exceeded at M&O contractor drinking water systems.
During 2004, 435 routine samples and 55 quality control samples were collected and analyzed from CFA, EBR-I, Gun Range, INTEC, Main Gate, Power Burst Facility (PBF), RWMC, TAN/Contained Test Facility (CTF), TAN/TSF, and TRA. In addition to the routine sampling, the M&O contractor Drinking Water Program also collects nonroutine samples. A nonroutine sample is one collected after a water main breaks and is repaired to determine if the water is acceptable for use before the main is put back into service. Fifty requests for nonroutine sampling were received during 2004.
Analytical results of interest (carbon tetrachloride, trichloroethylene, and tritium) and nitrate (required to be monitored annually) results for 2004 are presented in Table 5-21 and Table 5-22, respectively, and are discussed in the following subsections. EBR-I, Gun Range, INTEC, Main Gate, PBF, and TAN/CTF were well below drinking water limits for all regulatory parameters; therefore, they are not discussed further in this report.
In 2004, total coliform and fecal coliform bacteria were absent in all M&O contractor-operated water systems at the INEEL. No MCL exceedances occurred during 2004 for any parameter.
Central Facilities Area - The CFA water system serves approximately 900 people daily. Since the early 1950s, wastewater containing tritium was disposed to the Eastern Snake River Plain Aquifer at INTEC and TRA through injection wells and infiltration ponds. These wastewaters migrated south southwest and are the suspected source of tritium contamination in the CFA water supply wells. The practice of disposing of wastewater through injection wells was discontinued in the mid-1980s.
In 2004, water samples were collected quarterly from CFA #1 Well (at CFA-651), CFA #2 Well (at CFA-642), and CFA-1603 (point of entry to the distribution system) for compliance purposes. Since December 1991, the mean tritium concentration has been below the MCL at all three locations. In general, tritium concentrations in groundwater have been decreasing (Figure 5-1) because of changes in disposal techniques, recharge conditions, and radioactive decay.
CFA Worker Dose - Because of the potential impacts to downgradient workers at CFA from radionuclides in the aquifer, the potential effective dose equivalent from radioactivity in water was calculated. CFA was selected because tritium concentrations found in these wells were the highest of any drinking water wells. The 2004 calculation was based on
For the 2004 dose calculation, the assumption was made that each worker's total water intake came from the CFA drinking water distribution system. This assumption overestimates the dose because workers typically consume only about half their total intake during working hours and typically work only 240 days rather than 365 days per year. The estimated annual effective dose equivalent to a worker from consuming all their drinking water at CFA during 2004 was 0.47 mrem (4.7 µSv), below the EPA standard of 4 mrem/yr for public drinking water systems.
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Radioactive Waste Management Complex - The RWMC production well is located in WMF-603 and supplies all of the drinking water for more than 300 people at the RWMC. The well was put into service in 1974. Water samples were collected at the wellhead and from the point of entry to the distribution system, which is the point of compliance, at WMF-604.
Since monitoring began at RWMC in 1988, there had been an upward trend in carbon tetrachloride concentrations until 1999 (Figure 5-2). Since 1999, carbon tetrachloride concentrations have remained fairly constant. In October 1995, the carbon tetrachloride concentrations increased to 5.48 µg/L at the well. This was the first time the concentrations exceeded the maximum contaminant level of 5.0 µg/L. However, the maximum contaminant level for carbon tetrachloride is based on a four quarter average and does not apply to the well. The distribution system is the point from which water is first consumed at RWMC and is the compliance point. Table 5-23 summarizes the carbon tetrachloride concentrations at the RWMC drinking water well and distribution system for 2004. The mean concentration at the well for 2004 was 4.88 µg/L, and the maximum concentration was 5.0 µg/L. The mean concentration at the distribution system was 3.35 µg/L, and the maximum concentration was 3.4 µg/L.
A potential source of the carbon tetrachloride is the estimated 334,630 L (88,400 gal) of organic chemical wastes (including carbon tetrachloride, trichloroethylene, tetrachloroethylene, toluene, benzene, 1,1,1 trichloroethane, and lubricating oil) that were disposed of at the RWMC before 1970. High vapor-phase concentrations (up to 2,700 parts per million vapor phase) of volatile organic compounds were measured in the zone above the water table. Groundwater models predict that volatile organic compound concentrations will continue to increase in the groundwater at the RWMC.
Permanent chlorination was installed in 2003 because of a history of total coliform bacteria detections. Since permanent chlorination was installed, no coliform bacteria have been detected.
Test Area North/Technical Support Facility - In 1987, trichloroethylene was detected at both TSF #1 and #2 Wells, which have supplied drinking water for up to 200 employees at TSF daily. The inactive TSF injection well (TSF-05) is believed to be the principal source of trichloroethylene contamination at the TSF. Bottled water was provided until 1988 when a sparger system (air stripping process) was installed in the water storage tank to volatilize the trichloroethylene to levels below the MCL.
During the third quarter of 1997, TSF #1 Well was taken offline, and TSF #2 Well was put online as the main supply well because the trichloroethylene concentration of TSF #2 had fallen below the MCL of 5.0 µg/L. Therefore, by using TSF #2 Well, no treatment (sparger air stripping system) is currently required. TSF #1 Well is used as a backup to TSF #2 Well. If TSF #1 Well must be used, the sparger system must be activated to treat the water.
Figure 5-3 illustrates the concentrations of trichloroethylene in both TSF wells and the distribution system from 1994 through 2004. Past distribution system sample exceedances are attributed to preventive maintenance activities interrupting operation of the sparger system.
Table 5-24 summarizes the trichloroethylene concentrations at TSF #2 Well and the distribution system. Regulations do not require sampling of TSF #2 Well; however, samples were collected to monitor trichloroethylene concentrations. The distribution system is the compliance point. TSF #1 Well was not sampled during 2004 because it was not required by the regulations and is not currently in use. The mean concentration of trichloroethylene at the distribution system for 2004 was 1.40 µg/L, which is below the MCL.
During 2004, ANL-W analyzed quarterly water samples for gross alpha, gross beta, and tritium collected from a point prior to water entry to the drinking water distribution system, in accordance with the Safe Drinking Water Act. Values for both gross alpha concentration and gross beta concentration were well below MCLs. No detectable concentrations of tritium were reported.
ANL-W collected an annual nitrate sample as required by regulation. Results were below the EPA MCL (Table 5-22). ANL-W also tested its system quarterly for coliform bacteria with no positive results for the year.
Drinking water samples were collected at a point before entering the distribution system. The samples were drawn from a sampling port immediately downstream from the NRF water softening treatment system. The water was monitored for nitrates, lead and copper. Radionuclides were sampled at each wellhead. Drinking water standards for these constituents were not exceeded at NRF.
No gross alpha, gross beta, gamma-emitters, or 90Sr were measured in excess of natural background concentrations in 2004. Tritium values were not detected above the minimum detection levels. For more information see Bechtel Bettis 2004.
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The EPA NPDES regulations for the point-source discharges of storm water to waters of the United States require permits for discharges from industrial activities (40 CFR 122.26 2003). Following these regulations, the Army Corps of Engineers and EPA are likely to assert that the waters of the United States at the INEEL are the
Together, the above locations comprise the Big Lost River System (Figure 5-4).
A Storm Water Monitoring Program was implemented in 1993 when storm water permits initially applied to the INEEL facilities. The program was modified as permit requirements changed, data were evaluated, and needs were identified. On September 30, 1998, the EPA issued the "Final Modification of the NPDES Storm Water Multi-Sector General Permit for Industrial Activities" (63 FR 189 1998) (referred to as the General Permit). The INEEL M&O contractor implemented the analytical monitoring requirements of the 1998 General Permit starting January 1, 1999. Visual monitoring was implemented starting October 1, 1998, and continues to be performed quarterly.
The General Permit was reissued in October 2000. The Idaho National Engineering and Environmental Laboratory Storm Water Pollution Prevention Plan for Industrial Activities was revised in 2002 (DOE-ID 2002) to meet the requirements of the reissued General Permit. The Storm Water Monitoring Program meets the General Permit requirements by conducting permit-required monitoring. The General Permit requires visual monitoring during the first, third, and fifth years of the permit’s duration and both analytical and visual monitoring on the second and fourth years. The General Permit requires that samples be collected and visually examined from rainstorms that accumulated at least 0.25 cm (0.1 in.) of precipitation preceded by at least 72 hrs without measurable precipitation (< 0.25 cm [< 0.1 in.]) to allow pollutants to build up and then be flushed from the drainage basin.
In addition to the above-discussed NPDES permit-required monitoring, the program monitors storm water to deep injection wells (three at TAN, three at PBF, and one at CFA) to comply with state of Idaho injection well permits. In 1997, responsibility for monitoring of storm water entering deep injection wells was transferred from the USGS to the M&O Storm Water Monitoring Program. Storm water data are reported as analytical data submitted to the EPA in a discharge monitoring report; as General Permit visual data and analytical data included in the annual revisions of the plan; or data for storm water discharged to deep injection wells reported to the Idaho Department of Water Resources.
Historically, storm water monitoring locations were based upon drainage patterns and proximity to potential sources of pollutants. The General Permit requires visual examinations of storm water for obvious indications of storm water pollution. In addition, visual examinations were conducted for surveillance purposes at some locations whether or not storm water discharged to the Big Lost River System.
In a letter dated October 27, 2003, to the DOE-ID chief counsel, EPA Region 10 determined that three sites at the INEEL (RWMC, INTEC, and the north part of the INEEL property near Birch Creek [area around TAN]) do not have a reasonable potential to discharge storm water to waters of the United States (Ryan 2003). A subsequent letter on December 15, 2003, from the DOE-ID contract officer to the M&O Prime Contracts manager directed the M&O contractor to cease expending further resources on compliance with the Storm Water Pollution Prevention Plan for Industrial Activities, Storm Water Pollution Prevention Plan for Construction Activities, and Spill Prevention Control and Countermeasures Programs at the three sites discussed in the letter from EPA (Bauer 2003). The letter further directed the M&O contractor to conduct a technical analysis to determine any other areas under the M&O contractor's control that would also have the same or less potential to discharge storm water to waters of the United States. As a result of this direction by DOE-ID, construction and industrial storm water inspections, data collection, and reports have ceased for projects located at those facilities.
The remaining projects were evaluated through the technical analysis requested by DOE-ID to determine potential to discharge. Required storm water inspections and reporting continued for these projects until October 2004. At that time, inspections and reports at any additional projects that had no reasonable potential to discharge to waters of the United States, as determined through the preliminary technical analysis (to be finalized in early 2005), ceased.
During 2004, the Storm Water Monitoring Program monitored the following facilities or activities:
During 2004, 2 visual storm water examinations were performed at two locations, and none performed at one location due to lack of storm water discharge. No discharge down any of the seven injection wells was observed; therefore, no visual examinations were performed or analytical samples collected at those locations.
The visual examinations performed in 2004 showed satisfactory implementation of the INEEL Storm Water Pollution Prevention Plan for Industrial Activities (DOE-ID 2002), and no corrective actions were required or performed during the year.
The General Permit does not contain numeric limitations for analytical parameters, except for pH limitations from runoff from coal piles, such as the one historically monitored at INTEC. Other parameters are compared to benchmark concentrations to help evaluate the quality of storm water discharges.
Analytical samples were collected for qualifying rain events that potentially discharged to waters of the United States at applicable monitoring locations. Discharge to waters of the United States from a qualifying storm occurred at the T-28 north gravel pit (TAN-MP-1/1 [inflow to gravel pit] and TAN-MP-2/1 [outflow from gavel pit]). Table 5-25 and Table 5-26 summarize the 2004 results and permit benchmark concentrations for these two locations. No benchmark concentrations were exceeded at the T-28 north gravel pit. Monitoring of this location (along with other gravel pits, which never discharged and therefore were never sampled) ceased in October 2004 based on preliminary results of the technical analyses, which will be published in early 2005.
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In compliance with DOE Order 435.1, the M&O contractor collects surface water, as surface runoff, at the Radioactive Waste Management Complex (RWMC) Subsurface Disposal Area (SDA). The control location for the RMWC SDA is 1.5 km (0.93 mi) west from the Van Buren Boulevard intersection on U.S. Highway 20/26 and 10 m (33 ft) north on the T-12 Road.
Surface water is collected to determine if radionuclide concentrations exceed alert levels or if concentrations have increased significantly compared to historical data.
Radionuclides could be transported outside the RWMC boundaries via surface water runoff. Surface water runs off at the SDA only during periods of rapid snowmelt or heavy precipitation. At these times, water may be pumped out of the SDA into a drainage canal, which directs the flow outside the RWMC. The canal also carries runoff from outside the RWMC that has been diverted around the SDA.
Because of drought conditions, no surface water runoff was available for sampling at the RWMC SDA during 2004.
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40 CFR 122.26, 2004, "Storm Water Discharges," Code of Federal Regulations, Office of the Federal Register.
40 CFR 141, 2004, "National Primary Drinking Water Regulations," Code of Federal Regulations, Office of the Federal Register.
40 CFR 142, 2004, "National Primary Drinking Water Regulations Implementation," Code of Federal Regulations, Office of the Federal Register.
40 CFR 143, 2004, "National Secondary Drinking Water Regulations," Code of Federal Regulations, Office of the Federal Register.
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.
Bauer, W., 2003, DOE-ID, to S. S. Crawford, BBWI "Actions in Regards to Environmental Protection Agency of the United States," CCN 46917, December 15, 2003.
Bechtel Bettis, 2004, 2004 Environmental Monitoring Report for the Naval Reactor Facility, NRFRC-EE-012.
Cascade Earth Science (CES), 1993, Soil Suitability Investigation for Land Application of Waste Water, Central Facility Area, Idaho National Engineering Laboratory, July 8, 1993.
DEQ, 1995, “Wastewater Land Application Permit No. LA-000115-02 for ICPP Sewage Treatment Plant.”
Hull, L. C., K. E. Wright, and L. V. Street, letter report to M. G. Lewis, July, 8, 2004, “Analysis of Suspended Solids in INTEC Percolation Pond Monitoring Wells,” CCN 54400.
IDAPA 58.01.08, "Idaho Regulations for Public Drinking Water Systems," Idaho Administrative Procedures Act, State of Idaho Department of Health and Welfare, current revision.
IDAPA 58.01.11, "Ground Water Quality Rules," State of Idaho Department of Health and Welfare, current revision.
IDAPA 58.01.17, "Wastewater Land Application Permits," Idaho Administrative Procedure Act, State of Idaho Department of Health and Welfare, current revision.
Johnston, J., 2001, DEQ, to Stacey Madson, DOE-ID, "INEEL Test Reactor Area (TRA) Cold Waste Pond and Water Reactor Test Facility (WRRTF) Wastewater Disposal Ponds," January 19, 2001.
Ryan, M., 2003, EPA Region 10, to A. E. Gross, DOE-ID, "Storm Water Compliance at the INEEL," CCN 46063, October 27, 2003.
U.S. Department of Energy (DOE), 2003, "Environmental Protection Program," DOE Order 450.1, January.
U.S. Department of Energy (DOE), 1993, "Radiation Protection of the Public and the Environment," DOE Order 5400.5, January.
U.S. Department of Energy-Idaho Operations Office (DOE-ID), 2002, Idaho National Engineering and Environmental Laboratory Storm Water Pollution Prevention Plan for Industrial Activities, DOE/ID-10431, Rev. 41, January.
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