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B. Jonker - U.S. Department of Energy - Idaho Operations Office
M. Case - S. M. Stoller Corporation
Operations at the Idaho National Laboratory (INL) Site are subject to numerous federal and state environmental statutes, executive orders, and U.S. Department of Energy (DOE) orders. As a requirement of many of these regulations, the status of compliance with the regulations and releases of nonpermitted hazardous materials to the environment must be documented. Overall, the INL Site met all its regulatory commitments in 2005 and programs are in place to address areas for continued improvement.
The following paragraphs highlight the accomplishments made in 2005.
Under a Federal Facility Agreement/Consent Order, signed in 1991, the INL Site was divided into ten Waste Area Groups containing 25 operable units, which are areas with similar contamination grouped within a single Record of Decision (ROD). The INL Site continues to make progress on remedial actions at operable units, as detailed in Chapter 3.
All Emergency Planning and Community Right-to-Know Act and Resource Conservation and Recovery Act reports were submitted as scheduled.
The state of Idaho approved closure plans for nine facilities.
The U. S. Department of Energy-Idaho Operations Office (DOE-ID) completed a Supplement Analysis of the 1995 Spent Fuel Environmental Impact Statement, concluding that the environmental restoration and waste management portion of the Environmental Impact Statement (EIS) was still adequate for informing DOE decision-makers and the public of the environmental risks and impacts of actions taken for existing environmental restoration and waste management operations at the INL Site.
DOE-ID submitted the 2004 INL National Emission Standards for Hazardous Air Pollutants-Radionuclides report to U.S. Environmental Protection Agency, DOE Headquarters, and state of Idaho officials in June 2005, in compliance with the Clean Air Act.
The state of Idaho issued a Tier I operating permit under Title V of the Clean Air Act with an effective date of June 28, 2005.
In December 2005, DOE issued a ROD for the Idaho High-Level Waste and
Facilities Disposition Environmental Impact Statement.
DOE-ID completed the Save America’s Treasures matching funds grant for the Experimental Breeder Reactor-1, raising $320,000 to match the grant received from the National Park Service for preservation of this National Historic Landmark.
There are 59 active permits that have been granted to the INL Site from the City of Idaho Falls, State of Idaho, the U.S. Environmental Protection Agency, and the Corps of Engineers.
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This chapter reports the compliance status of the Idaho National Laboratory (INL) Site with environmental protection requirements. Section 2.1 discusses the compliance status of the INL Site with respect to major environmental acts, agreements, and orders. Section 2.2 discusses environmental occurrences, which are nonpermitted releases that require notification of a regulatory agency outside of the U.S. Department of Energy (DOE). Section 2.3 presents a summary of environmental permits for the INL Site. The programs in place to attain compliance with major acts, agreements, and orders are discussed in Chapter 3.
Operations at the INL Site are subject to numerous federal and state environmental statutes, executive orders, and DOE orders. These are listed in Appendix A. This section presents a brief summary of the INL’s compliance status with those regulations. Table 2-1 shows how the discussion is organized.
The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) provides the process to assess and remediate areas contaminated by the release of chemically hazardous and/or radioactive substances. Nuclear research and other operations at the INL Site left behind contaminants that pose a potential risk to human health and the environment. The INL Site was placed on the National Priorities List under CERCLA on November 29, 1989. The U. S. Department of Energy-Idaho Operations Office (DOE-ID), the state of Idaho, and the U.S. Environmental Protection Agency (EPA) Region 10 signed the Federal Facility Agreement and Consent Order (FFA/CO) in December 1991. The cleanup contractor, in accordance with the FFA/CO, is conducting environmental restoration activities at the INL Site.
The INL Site is divided into ten Waste Area Groups (WAGs) as a result of the FFA/CO. Field investigations are used to evaluate potential release sites within each WAG when existing data are insufficient to determine the extent and nature of contamination. After each investigation is completed, a determination is made whether a “No Further Action” listing is possible or if it is appropriate to proceed with an interim cleanup action or further investigation using a remedial investigation/feasibility study (RI/FS). Results from the RI/FS form the basis for assessment of risks and alternative cleanup actions. This information, along with the agencies proposed cleanup plan is presented to the public in a document called a Proposed Plan. After reviewing public comments, DOE-ID, EPA, and the State reach a final cleanup decision, which is documented in a Record of Decision (ROD). Cleanup activities then can be designed, implemented, and completed. Specific environmental restoration activities are discussed in Chapter 3.
Natural Resource Trusteeship and Natural Resources Damage Assessment – Executive Order 12580, Section 2(d), appoints the Secretary of Energy as the primary Federal Natural Resource Trustee for natural resources located on, over, and under land administered by DOE. Natural resource trustees act on behalf of the public when natural resources may be injured, destroyed, lost, or threatened as a result of the release of hazardous substances. In the case of the INL Site, other natural resource trustees with jurisdiction over trust resources are the state of Idaho and U.S. Department of Interior (Bureau of Land Management and the U.S. Fish and Wildlife Service).
Past releases of hazardous substances resulted in the INL’s Site placement on the National Priorities List. These same releases created the potential for injury to natural resources. DOE is liable under CERCLA for damages to natural resources resulting from releases of hazardous substances to the environment.
Although the ecological risk assessment is a separate effort from the Natural Resources Damage Assessment, it is anticipated that the ecological assessment performed for CERCLA remedial actions can be used to help resolve natural resource issues. Ecological risk assessments at the INL Site have been conducted using the established guidance manual for conducting screening level ecological risk assessments (Van Horn et al. 1995).
The Emergency Planning and Community Right-to-Know Act (EPCRA) provides the public with information about hazardous chemicals at a facility (such as the INL Site) and establishes emergency planning and notification procedures to protect the public from chemical releases. EPCRA also contains requirements for periodic reporting on hazardous chemicals stored and/or used at a facility. Executive Order 13148, “Greening the Government through Leadership in Environmental Management,” requires all federal facilities to comply with the provisions of EPCRA.
311 Report – EPCRA Section 311 reports were submitted quarterly for those chemicals that met the threshold planning quantity. These reports were sent to local emergency planning committees, the State Emergency Response Commission, and to local fire departments for each quarter in calendar year 2005. These quarterly reports satisfied the 90-day notice requirement for new chemicals brought onsite.
312 Report – Local and State planning and response agencies received the Emergency and Hazardous Chemical Inventory (Tier II) Report for 2005 by March 1, 2005. This report identified the types, quantities, and locations of hazardous and extremely hazardous chemicals stored at INL Site facilities that exceeded:
313 Report – The Toxic Chemical Release Inventory Report was transmitted to the EPA and the state of Idaho July 1, 2006. The report identifies quantities of 313-listed toxic chemicals that were used/released above an activity threshold. Once these activity thresholds (for manufacturing, processing, or otherwise used) are exceeded, an EPA 313 Toxic Release Inventory Form R report must be completed for each specific chemical. Releases under EPCRA reporting include transfers to offsite waste storage and treatment, air emissions, recycling, and other activities. Ten reports were prepared at the INL Site during 2005 for toluene, ethylbenzene, lead and lead compounds, nitric acid, naphthalene, propylene, xylene, 1,2,4-trimethylbenzene, nickel, and polycyclic aromatic compounds. The 313 reports vary year-to-year depending upon the chemical processes at the Site.
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The National Environmental Policy Act (NEPA) requires federal agencies to consider and analyze potential environmental impacts of proposed actions and explore appropriate alternatives to mitigate those impacts, including a “no action” alternative. Agencies are required to inform the public of the proposed actions, impacts, and alternatives and consider public feedback in selecting an alternative. DOE implements NEPA according to procedures in 10 CFR 1021 and assigns authorities and responsibilities according to DOE Order 451.1B, “National Environmental Policy Act Compliance Program.” Processes specific to DOE-ID are set forth in its NEPA Planning and Compliance Program Guidance (DOE-ID 2005). The DOE-ID NEPA Compliance Officer and NEPA Planning Board implement the process.
The DOE-ID issued the Annual NEPA Planning Summary in January 2005. That summary is a requirement of DOE Order 451.1B, and it is prepared to inform the public and other DOE elements of:
Ongoing NEPA reviews of INL Site projects are described below.
Idaho High-Level Waste and Facilities Disposition Environmental Impact Statement (Idaho HLW & FD EIS) – This EIS describes the potential environmental impacts of various alternatives for treating and managing high-level radioactive waste and related radioactive wastes and facilities at the Idaho Nuclear Technology and Engineering Center (INTEC). DOE received and considered agency and public comments on a draft EIS. In response to those comments and updated information, DOE incorporated changes into the final EIS. The final EIS was issued in the fall of 2002.
DOE planned for a phased decision-making process. In December 2005, DOE issued a ROD for the Idaho HLW & FD EIS. DOE decided to treat sodium–bearing liquid waste using the steam reforming technology; conduct performance-based closure on all existing facilities directly related to the High-Level Waste (HLW) Program at INTEC, except for the INTEC Tank Farm Facility and bin sets, once their missions are complete; design and construct new waste processing facilities needed to implement the decisions in the ROD consistent with clean closure methods and planned to be clean closed when their missions are complete; and develop HLW calcine retrieval demonstration process and conduct risk-based analysis, including disposal options, focused on the calcine stored at INTEC.
An amended ROD addressing closure of the INTEC Tank Farm Facility will be issued in coordination with the Secretary of Energy’s determination, in consultation with the Nuclear Regulatory Commission, under Section 3116 of the Fiscal Year 2005 Ronald W. Reagan National Defense Authorization Act expected in calendar year 2006. An additional ROD for HLW calcine disposition and bin set closure is scheduled for issuance in 2009.
Supplement Analysis of Spent Fuel EIS – In late 2004, DOE began
preparation of a supplement analysis (SA) to compare environmental restoration
and waste management projects identified in Volume 2 of the 1995 DOE
Programmatic Spent Nuclear Fuel Management and Idaho National Laboratory
Environmental Restoration and Waste Management Programs Final Environmental
Impacts Statement (DOE 1995) with updated INL plans and prevailing environmental
baseline conditions. The SA was completed in June 2005 and made available to the
public. DOE concluded the environmental restoration and waste management portion
of the 1995 EIS was still adequate for informing DOE decision-makers and the
public of the environmental risks and impacts of actions taken within the scope
of Volume 2 and for existing environmental restoration and waste management
operations at the INL Site. DOE also concluded that there were no new
significant circumstances, information, or changes identified within the
analysis of Volume 2 that would compel preparation of a new EIS or Supplemental
EIS for current INL Site environmental restoration and waste management
Environmental Assessment for the Remote Treatment Project - The proposed action is to provide heavily shielded remote waste handling services for the Materials and Fuels Complex and INL Site legacy and newly generated remote handled (RH) waste. The project would include a shielded hot cell with equipment for sorting, characterizing, treating and repackaging highly radioactive transuranic, mixed, and other radioactive waste. The facility mission is to make RH radioactive wastes ready for shipment to disposal locations. Much of the proposed action was analyzed in the Programmatic Spent Nuclear Fuel Management and Idaho National Engineering Laboratory Environmental Restoration and Waste Management Programs Final EIS (DOE 1995) as the Remote Mixed Waste Treatment Facility project. DOE notified the state of Idaho and Shoshone-Bannock Tribal contacts in January of 2001. The draft EA is scheduled for public comment in 2006.
Environmental Assessment for the Dynamic Test of PIDAS Elements and Protective Vehicles - The proposed action would be to conduct two security technology systems tests. The proposed project would consist of two explosive events conducted over an 18-month period. The draft EA was made available to the public in August 2005. The EA was subsequently cancelled. The proposed activities will be included in a new EA for a proposed project titled “Security Systems Test Range.” Comments received on the draft Dynamic Test of PIDAS Elements and Protective Vehicles EA will be considered during the development of the new EA.
The Endangered Species Act provides a means whereby the ecosystems upon which endangered species and threatened species depend may be conserved, provides a program for the conservation of such endangered species and threatened species, and takes such steps as may be appropriate to achieve the purposes of the international treaties and conventions on threatened and endangered species. It requires that all federal departments and agencies shall seek to conserve endangered species and threatened species and shall use their authorities in furtherance of the purposes of this act.
The Environmental Surveillance, Education and Research Program conducts ecological research, field surveys, and NEPA evaluations regarding ecological resources on the INL Site. Particular emphasis is given to threatened and endangered species and species of special concern identified by the U.S. Fish and Wildlife Service and Idaho Fish and Game Department.
Two federally protected species may occasionally spend time on the INL Site: the threatened bald eagle (Haliaeetus leucocephalus) and the gray wolf (Canis lupus). Gray wolves found in the geographical region that includes the INL Site are identified as an experimental/nonessential population and treated as a threatened species. Bald eagles occasionally winter on part of the INL Site, and there have been unsubstantiated sightings of gray wolves. Research and monitoring continued on several species of special biological, economic, and social concern, including Townsend’s big-eared bat (Corynorhinus townsendii), sage grouse (Centrocercus urophasianus), elk (Cervus elaphus), and pronghorn antelope (Antilocapra americana).
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Executive Order 11988 – Floodplain Management requires each federal agency to issue or amend existing regulations and procedures to ensure that the potential effects of any action it may take in a floodplain are evaluated and that its planning programs and budget requests reflect consideration of flood hazards and floodplain management. It is the intent of this Executive Order that federal agencies implement floodplain requirements through existing procedures such as those established to implement NEPA. The Code of Federal Regulations (10 CFR 1022) contains DOE policy and floodplain environmental review and assessment requirements through the applicable NEPA procedures (10 CFR 1022). In those instances where impacts of actions in floodplains are not significant enough to require the preparation of an EIS under NEPA, alternative floodplain evaluation requirements are established through the INL Site environmental checklist process.
For the Big Lost River, DOE-ID has directed that all proposed actions be reviewed to identify their location relative to the elevation of the 100-year flood indicated in Flood Routing Analysis for a Failure of Mackay Dam for purposes of the NEPA compliance (Koslow and VanHaaften 1986). This analysis involved a 100-year flood in conjunction with the Mackay Dam failure. This direction is considered to be interim and remains in effect until DOE-ID issues a final determination of the 100- and 500-year Big Lost River flood elevations. Projects to delineate the Big Lost River 100-year through 10,000-year floodplains using geomorphological models and hydrologic analysis to characterize and estimate the frequency and magnitude of Big Lost River floods on the INL Site have been conducted. The hydrologic analysis is published in Estimating the Magnitude of the 100-Year Peak Flow in the Big Lost River at the Idaho National Engineering and Environmental Laboratory, Idaho (Hortness and Rousseau 2003). A flood hazard report based on the geomorphological models was drafted and has undergone peer review in 2004. Evaluations of the determinations are ongoing and they will be analyzed by DOE-ID for implementation upon completion.
For facilities at Test Area North (TAN), the 100-year floodplain has been delineated in a U.S. Geological Survey (USGS) report (USGS 1997).
Executive Order 11990 – Protection of Wetlands requires each federal agency to issue or amend existing regulations and procedures to ensure wetlands are protected in decision-making. It is the intent of this executive order that federal agencies implement wetland requirements through existing procedures such as those established to implement NEPA. The 10 CFR 1022 statute contains DOE policy and wetland environmental review and assessment requirements through the applicable NEPA procedures. In those instances where impacts of actions in wetlands are not significant enough to require the preparation of an EIS under NEPA, alternative wetland evaluation requirements are established through the INL Site environmental checklist process. Activities in wetlands considered waters of the United States or adjacent to waters of the United States may also be subject to the jurisdiction of Section 404 and 402 of the Clean Water Act.
The only area of the INL Site identified as potentially jurisdictional wetlands is the Big Lost River Sinks. The U.S. Fish and Wildlife Service National Wetlands Inventory map is used to identify potential jurisdictional wetlands and nonregulated sites with ecological, environmental, and future development significance. In 2005, no actions took place or had an impact on potentially jurisdictional wetlands on the Site, and, to date, no future actions are planned that would impact wetlands. However, private parties do conduct cattle grazing in the Big Lost River Sinks area under Bureau of Land Management permits.
The Resource Conservation and Recovery Act (RCRA) established regulatory standards for generation, transportation, storage, treatment, and disposal of hazardous waste. The Idaho Department of Environmental Quality (DEQ) is authorized by EPA to regulate hazardous waste and the hazardous components of mixed waste at the INL Site. Mixed waste contains both radioactive and hazardous materials. The Atomic Energy Act, as administered through DOE Orders, regulates radioactive wastes and the radioactive part of mixed wastes.
Idaho DEQ has issued two RCRA Part A permits for the INL Site and seven Part B permits. One additional Part B permit is pending. DOE-ID, Battelle Energy Alliance (BEA), CH2M-WG Idaho, Bechtel BWXT Idaho, and Idaho DEQ meet quarterly to discuss RCRA-related issues. Summaries of the meetings can be accessed at http://idahocleanupproject.inel.gov/PublicInfo/tabid/84/Default.aspx.
Notices of Violation/Non-compliance – On October 18-20, 2005, EPA conducted an inspection of DOE-ID owned and contractor operated petroleum underground storage tanks (UST) located at Idaho Falls Facilities (IFF) and the Materials and Fuels Complex (MFC). The EPA inspector issued a UST Field Notice of Non-compliance (NON) to BEA on October 20, 2005 for the following alleged non-compliance issues: (1) failure to provide 12 months of passing tank leak tests for a UST at MFC, (2) failure to verify adequate cathodic protection on piping by not testing and providing conductivity measurements every three years for a UST at MFC, and (3) failure to install vent piping in accordance with industry standards for a UST at MFC and a UST at an IFF building. BEA provided documentation to the EPA by the required due date and the EPA dismissed the NON.
RCRA Closure Plans – The state of Idaho approved closure plans for the following facilities in 2005:
RCRA Reports – As required by the state of Idaho, the INL Site submitted the Idaho Hazardous Waste Generator Annual Report for 2005. The report contains information on waste generation, treatment, recycling, and disposal activities at INL Site facilities.
DOE-ID submitted the INL Site 2005 Affirmative Procurement Report to the EPA, as required by Section 6002 of RCRA and Executive Order 13101, Greening the Government through Waste Prevention, Recycling, and Federal Acquisition. This report provides information on the INL’s Site procurement of products with recycled content.
The INL Site RCRA permit for the Hazardous Waste Storage Facility at the Central Facilities Area (CFA) and some areas at the MFC requires submittal of an annual certification to Idaho DEQ that the INL Site has a waste minimization program in place to reduce the volume and toxicity of hazardous waste. The certification was submitted by July 1, 2005.
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The Federal Facility Compliance Act requires the preparation of site treatment plans for the treatment of mixed wastes stored or generated at DOE facilities. Mixed waste contains both hazardous and radioactive components. The INL Site Proposed Site Treatment Plan was submitted to the state of Idaho and EPA on March 31, 1995. This plan outlined DOE‑ID’s proposed treatment strategy for INL Site mixed waste streams, called the “backlog,” and provided a preliminary analysis of potential offsite mixed low-level waste treatment capabilities.
The INL Site Proposed Site Treatment Plan formed the basis for negotiations between the state of Idaho and DOE-ID on the consent order for mixed waste treatment at the INL Site. The Federal Facility Compliance Act Consent Order and Site Treatment Plan were finalized and signed by the state of Idaho on November 1, 1995.
A status of Site Treatment Plan milestones for 2005 is provided in Chapter 3.
The Toxic Substances Control Act (TSCA), which is administered by EPA, requires regulation of production, use, or disposal of chemicals. TSCA supplements sections of the Clean Air Act, the Clean Water Act, and the Occupational Safety and Health Act. Because the INL Site does not produce chemicals, compliance with TSCA at the INL Site is primarily directed toward use and management of certain chemicals, particularly polychlorinated biphenyls (PCBs). Removal of PCB containing light ballasts continues at buildings undergoing demolition. The ballasts are disposed of off-site in a TSCA-approved disposal facility. One ballast had a release and the area was cleaned per regulatory requirements.
DOE Order 435.1, “Radioactive Waste Management,” was issued to ensure that all DOE radioactive waste is managed in a manner that protects the environment and worker and public safety and health. This Order, effective July 1, 1999, replaces DOE Order 5820.2A, “Radioactive Waste Management,” and includes the requirements that DOE facilities and operations must meet in managing radioactive waste. INL Site activities related to this Order are discussed in Chapters 3 and 6.
DOE-ID has applied for state of Idaho Wastewater Land Application Permits (WLAP) for all existing land application facilities. Permit renewal applications for the CFA Sewage Treatment Plant and TAN/Technical Support Facility Sewage Treatment Plant are under consideration by Idaho DEQ. Until the renewal permits are finalized, Idaho DEQ has authorized continued use of these facilities under the terms and conditions of the original permits.
Idaho DEQ issued a new WLAP permit for the combined INTEC Sewage Treatment Plant effluent and service wastewater for disposal at the new INTEC percolation ponds in 2004. The combined discharge commenced in December 2, 2004, and the separate INTEC Sewage Treatment Plant WLAP and INTEC New Percolation Pond WLAP were terminated at that time. Idaho DEQ is reviewing permit applications for the TRA Cold Waste Ponds, the Naval Reactors Facility Industrial Waste Ditch, and the Argonne National Laboratory-West industrial and sanitary waste ponds.
On October 16, 1995, DOE, the U.S. Navy, and the state of Idaho entered into an agreement that guides management of spent nuclear fuel and radioactive waste at the INL Site. The Agreement makes Idaho the only state with a federal court-ordered agreement limiting shipments of DOE and Naval spent nuclear fuel into the State and setting milestones for shipments of spent nuclear fuel and radioactive waste out of the State.
In 2005, there were no scheduled Settlement Agreement milestones. Progress was made toward meeting future milestones, including waste and spent nuclear fuel shipments. In 2005, 4267 m3 (150,688 ft3) of transuranic waste were shipped out of Idaho and the INL Site received truck cask shipments containing a combined total of 0.0535 metric tons (118 lbs) heavy metal from State University of New York–Buffalo, Argonne National Laboratory–East, and the North Anna Power Plant.
On December 13, 2005, DOE issued a ROD for the Facilities Disposition Environmental Impact Statement. This ROD chose the steam reforming technology to treat the remaining sodium-bearing liquid waste in the INTEC Tank Farm. DOE plans on completing the treatment using this technology by December 31, 2012.
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The Clean Air Act is the law that forms the basis for the national air pollution control effort. Basic elements of the act include national ambient air quality standards for major air pollutants, hazardous air pollutant standards, state attainment plans, motor vehicle emissions standards, stationary source emissions standards and permits, acid rain control measures, stratospheric ozone protection, and enforcement provisions.
The EPA is the federal regulatory agency of authority, but states may administer and enforce provisions of the act by obtaining EPA approval of a state implementation plan. Idaho has been delegated such authority.
The Idaho air quality program is primarily administered through the permitting process. Potential sources of air pollutants are evaluated against regulatory criteria to determine if the source is specifically exempt from permitting requirements and if the source’s emissions are significant or insignificant. If emissions are determined to be significant, several actions may occur:
Permitted sources of air pollutants at the INL Site are listed in Table 2-2.
Title V Operating Permit – Title V of the 1990 Clean Air Act Amendments required the EPA to develop a federally enforceable operating permit program for air pollution sources to be administered by state and/or local air pollution agencies. The EPA promulgated regulations in July 1992 that defined the requirements for state programs. Idaho has promulgated regulations and EPA has given interim approval of the Idaho Title V (Tier I) Operating Permit program. The INL Site was issued a Tier I operating permit with an effective date of June 28, 2005.
National Emission Standards for Hazardous Air Pollutants – DOE-ID submitted the 2005 INL National Emission Standards for Hazardous Air Pollutants-Radionuclides report to EPA, DOE Headquarters, and state of Idaho officials in June. This statute requires the use of the CAP-88 computer model to calculate the hypothetical maximum individual effective dose equivalent to a member of the public resulting from INL Site airborne radionuclide emissions. The 2005 calculations for this code are discussed further in Chapter 7, “Dose to the Public.”
The Clean Water Act (CWA), passed in 1972, established goals to control pollutants discharged to U.S. surface waters. Among the main elements of the CWA are effluent limitations, set by the EPA, for specific industry categories and water quality standards set by states. The CWA also provided for the National Pollutant Discharge Elimination System (NPDES) permit program, requiring permits for discharges from a point source into surface waters.
The INL Site complies with four CWA permits through the implementation of procedures, policies, and best management practices. The four permits are:
National Pollutant Discharge Elimination System Permits – The City of Idaho Falls is authorized by the NPDES permit program to set pretreatment standards for nondomestic discharges to publicly owned treatment works. This program is set out in the Municipal Code of the City of Idaho Falls regulations in Chapter 1, Section 8. Industrial Wastewater Acceptance Forms are obtained for facilities that discharge process wastewater through the City of Idaho Falls sewer system. Twelve Idaho Falls facilities 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. All discharges from Idaho Falls facilities in
2005 were within compliance levels established on the acceptance forms.
Storm Water Discharge Permits for Industrial Activity – The EPA issued a letter in October 2003, stating that they determined that INTEC, RWMC, and TAN do not have a reasonable potential to discharge storm water to waters of the United States. In December 2003, DOE-ID directed the Management and Operating contractor to cease storm water activities at those locations and complete a technical analysis based on the EPA statements to determine if other locations at the INL Site also do not have a reasonable potential to discharge. The technical analysis completed in 2005 determined that the industrial activities at the INL site do not have a potential to discharge because of the distance from the river and/or physical features that prevent discharges from reaching it. Notices of Termination for coverage under the Nationwide permit program were submitted to EPA Region 10.
Storm Water Discharge Permits for Construction Activity – INL Site’s General Permit for Storm Water Discharges from Construction Sites was issued in June 1993. The permit has been renewed twice since issuance. The INEEL Storm Water Pollution Prevention Plan for Construction Activities was most recently revised in 1998 (DOE-ID 1998). The plan provides for measures and controls to prevent pollution of storm water from construction activities at the INL Site. Worksheets are completed for construction projects and are appended to the plan. Inspections of construction sites are performed in accordance with permit requirements.
The regulatory basis for storm water discharge from construction sites is the same as for industrial activities; therefore, the technical analysis also reduced the area under the purview of the Storm Water for Construction Activities program.
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The Safe Drinking Water Act was reauthorized on August 6, 1996. It establishes primary standards for water delivered by systems supplying drinking water to 15 or more connections or 25 individuals for at least 60 days per year. The INL Site drinking water supplies meet these criteria for public water systems and are classified as either nontransient noncommunity or transient noncommunity systems. The INL Site has 12 active public water systems, one of which serve the Naval Reactors Facility. All facilities at the INL Site perform sampling of drinking water as required by the State and EPA. Chapter 5 contains details on drinking water monitoring results.
Preservation of historic properties on lands managed by DOE is mandated under Section 106 of the National Historic Preservation Act of 1966, as amended. The Act requires that for any federal project that may have an adverse effect on a historic property, the agency in charge of the project must take actions to mitigate those adverse effects. This is usually done through a Memorandum of Agreement with the State Historic Preservation Office.
DOE-ID, the DOE Federal Preservation Officer, and the Idaho State Historic Preservation Office (SHPO) entered into a Memorandum of Agreement to mitigate the adverse effects of the proposed decontamination, decommissioning, and demolition of four INL Site “Signature Properties” located at TAN and the Reactor Technology Complex. Signature Properties as defined in the INL Site Cultural Resource Management Plan (CRMP), is a term coined by DOE-Headquarters that denotes its most historically important properties across the complex and/or those properties that are viewed as having tourism potential. The TAN Hot Shop (TAN-607), the LOFT Control and Equipment Building (TAN-630), LOFT Containment and Service Building (TAN-650), and the Materials Test Reactor Building (TRA-603) are slated for demolition as part of Environmental Management Idaho Cleanup Project.
DOE-ID submitted the draft Historic American Engineering Record (HAER) report for the Reactor Technology Complex to the National Park Service (NPS). The HAER report focuses on the Engineering Test Reactor and the Materials Test Reactor and contains written and photographic documentation of these historic reactor buildings. The report also contains written and photographic documentation for direct and indirect support buildings for the two reactor buildings.
The INL Site CRMP underwent its first revision in September 2005. The CRMP provides a tailored approach for the INL Site to comply with Section 106 of the National Historic Preservation Act. The Programmatic Agreement between DOE-ID, the Advisory Council on Historic Preservation, and the Idaho SHPO, dated July 2004, Concerning Management of Cultural Resources on the Idaho National Laboratory Site, formally implements the CRMP.
DOE-ID completed the Save America’s Treasures matching funds grant for Experimental Breeder Reactor No. 1 (EBR-I) National Historic Landmark. DOE-ID received the $320,000 grant in May 1999 from the NPS and entered into an Interagency Agreement with the NPS to receive the funds and agree upon preservation activities for EBR-I. The funds were used to repair/replace damaged brick on the exterior of the reactor building and for new interpretive displays on EBR-I history at the reactor building. The grand opening for the new displays was held May 24, 2005.
The INL Site is located on the aboriginal territory of the Shoshone and Bannock people. The Shoshone-Bannock Tribes are major stakeholders in INL Site activities. They are particularly concerned with how the remains of their ancestors and culture are treated by DOE-ID and its contractors. The Native American Graves Protection and Repatriation Act provides for the protection of Native American remains and the repatriation of human remains and associated burial objects. Repatriation refers to the formal return of human remains and cultural objects to the Tribes with whom they are culturally affiliated.
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In 2005, three releases were deemed reportable to external regulatory agencies:
None of these releases posed significant threats to the environment or human health. All releases were appropriately remediated.
Table 2-2 summarizes permits applied for, and granted to, the INL Site through year-end 2005.
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Hortness, J.E., and Rousseau, J.P., 2003, Estimating the Magnitude of the 100-Year Peak Flow in the Big Lost River at the Idaho National Engineering and Environmental Laboratory, Idaho: U.S. Geological Survey Water-Resources Investigation Report 02-4299 (DOE/ID 22181), 36 p.
Koslow, K.N. and VanHaaften, D.H., 1986, Flood Routing Analysis for a Failure of Mackay Dam, EG&G EP-7184.
U.S. Department of Energy Idaho Operations Office (DOE-ID), 2005, Guidance for National Environmental Policy Act (NEPA) Planning and Compliance Program, OD-110-WI-112 Guidance, November 21.
U.S. Department of Energy Idaho Operations Office (DOE-ID), 1998, Idaho National Engineering and Environmental Laboratory Storm Water Pollution Prevention Plan for Construction Activities, DOE/ID-10425, Rev. 2, May.
U.S. Department of Energy Idaho Operations Office (DOE-ID), 1995, Department of Energy Programmatic Spent Nuclear Fuel Management and Idaho National Engineering Laboratory Environmental Restoration and Waste Management Programs Final Environmental Impact Statement. DOE/EIS-0203-F.
U.S. Geological Survey (USGS), 1997, Simulation of Water-Surface Elevations for a Hypothetical 100-Year Peak Flow in Birch Creek at the Idaho National Engineering and Environmental Laboratory, Idaho, DOE/ID-22138.
VanHorn, R.L., Hampton, N.L., and Morris, R.C., 1995, Guidance Manual for Conducting Screening Level Ecological Risk Assessments at the INEL, INEL-95/0190, June.
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