The following question was asked by a member of the public during the ICP CAB's June 20, 2019 meeting in Fort Hall, Idaho. The answer is provided by DOE-ID staff.
Now that the Idaho Cleanup (Project) is on the last Accelerated Retrieval Project (ARP IX) to exhume buried waste, how many curies of Americium-241 are remaining buried at the Subsurface Disposal Area (SDA)?
Answer: The performance objective for targeted waste retrieval was established in a record of decision agreed to by the regulators that states: “Completion of targeted waste retrieval will be measured by the volume of targeted waste retrieved. A minimum volume of targeted waste of 6,238 m3 will be retrieved from a minimum of 5.69 acres…, with the need for additional retrievals, if necessary, determined pursuant to CERCLA.” Therefore, the performance objective is based on the volume of targeted waste removed, not the removal of Am-241 curies from the SDA.
The following questions were asked by a member of the public during the ICP CAB's April 25, 2019 meeting in Twin Falls, Idaho. Answers are provided by DOE-ID staff.
For Integrated Waste Treatment Unit (IWTU) emissions, the phrase “continuous monitoring” is used. What will be monitored continuously and specifically what radiological emissions monitoring will be conducted?
Answer: The Resource Conservation and Recovery Act (RCRA) permit requires that the IWTU be “continuously monitored.” Attachment 1, Section D of the permit states that continuous monitoring of CO and O2 with a Continuous Emissions Monitoring System (CEMS) is used. The permit states that if CO concentrations using the two CEMS measurements from A-H-941-3A and A-H-941-3B are above or equal to 100 parts per million on an hourly rolling average, then an Automatic Waste Feed Cutoff actuates.
The air permit states that we shall comply with the requirements specified in 40 CFR 61, Subpart H and that emissions of radionuclides to the ambient air from DOE facilities shall not exceed those amounts that would cause any member of the public to receive, in a year, an effective dose of 10 millirem per year. Compliance with 40 CFR 61, Subpart H is accomplished by in-line stack sampling for radionuclide emissions from a particulate filter and activated charcoal filter, referred to as the Radionuclide Monitoring System (RMS). The particulate filter is analyzed using an approved EPA method (Method 114) for Gamma emitters (Cs-137, Ba-137m), total Sr-90, and Actinides (Am-241, Pu-238, Pu-239/240). The activated charcoal filter will also be analyzed using an approved EPA test method (Method 114) and will be analyzed for I-129.
The frequency for sampling the RMS is outlined in the document, “Quality Assurance Project Plan for the IWTU STK-SRE-140 Radiological Emissions Sampling System.” The particulate filter will be sampled once per week for the first four weeks of operation, then monthly for the remainder of the project. The activated charcoal filter is sampled quarterly for the entirety of the project. All sample data from the RMS is used to comply with the reporting requirements of 40 CFR 61.93.
Regarding the Defense Nuclear Facility Safety Board reports saying INL has not adequately addressed methane or hydrogen drum explosion, when and what does Fluor intend to do to address this?
Answer: There was no explosion during the April 11, 2018 event at the Accelerated Retrieval Project V facility, nor was hydrogen a contributing factor. The event was caused by the heating of unoxidized uranium that led to the hydrolysis reaction of beryllium carbide that resulted in rapid methane gas generation of sufficient pressure to overcome the drum lids.
Following the event and after extensive modeling, chemical compatibility reviews, and operating experience integration, new controls were established to monitor and prevent recurrence of these reactions. Procedures now require that workers rake through the waste material and hold it for a 24-hour period and perform thermal monitoring to look for elevated temperatures indicative of an on-going reaction. Jensen Hughes, a nationally recognized fire science consulting company, reviewed the controls to ensure they mitigate the risk and meet acceptable industry standards and practices. While the ARP V event involved pressurization, Jensen Hughes also looked more broadly at approaches for dealing with drums that may exceed the Lower Flammability Limit and concluded that they are sound and consistent with industry practice.
Beginning in September 2018, Fluor Idaho implemented the new controls for exhumed waste at the Accelerated Retrieval Project VIII facility (which has since been completed). Since then, the process has been employed on waste in the Accelerated Retrieval Project V facility, and currently in the Accelerated Retrieval Project IX facility. There have been no further adverse incidents.
Now that the IWTU may run radioactive material through it and emissions will be initially monitored, why isn’t IWTU required to meet EPA MACT (Maximum Achievable Control Technology) emissions limits? What constituents will exceed MACT limits?
Answer: The Idaho Department of Environmental Quality determined that the Integrated Waste Treatment Unit does not meet the definition of a hazardous waste combustor under federal regulations, and therefore direct regulation of the steam reformer emissions is not applicable. Performance testing of the system will be required, and DEQ will set the emission rates that are protective of human health and the environment. Additional emissions parameters, if found necessary after the performance test, could be established in the permit.
Isn’t the methane and hydrogen gas building in drums at DOE a complex-wide safety problem?
Answer: The hydrogen and methane gas presence in waste drums is a known phenomenon. Flammable gases may exist based on many sources, including petroleum products in certain waste, and such waste is monitored and controlled in accordance with regulations (such as RCRA, for example, when applicable) and facility permits as well as operational and worker safety limits.
DOE is taking action to ensure that lessons learned from this event are shared and understood. A Safety Alert was prepared and sent to EM waste sites to inform the EM complex of the potential vulnerability. In addition, an Occurrence Reporting and Processing System (ORPS) report was issued on the April 11, 2018 drum event at the Advanced Retrieval Project (ARP) V facility.
Where are quarantined drums – with gas or other conditions that don’t meet the WIPP WAC, stored? How many drums are there? What tracks their status?
Answer: We have 155 drums of TRU waste that still need additional work to meet the WIPP Waste Acceptance Criteria due to issues associated with flammable gas testing. These containers are stored in a number of locations such as the WMF- 636, Transuranic Storage Area- Retrieval Enclosure, or a Type II Storage Module (e.g., WMF-629, 630, 631, 632, or 633). They are tracked in the Waste Tracking System and are inspected per the RCRA permit requirements.
The following questions were asked by a member of the public during the ICP CAB's February 21, 2019 meeting in Idaho Falls, Idaho. Answers are provided by DOE-ID staff.
Waste Incidental to Reprocessing
Question: I cannot find documentation pertaining to the acceptance by the U.S. NRC of DOE-ID's proposed Waste Incidental to Reprocessing determination for the bulk of the sodium-bearing waste, other than NRC's agreement that criterion 1 was satisfied (no need for radionuclide separations). The NRC's acceptance of residual tank cleanout issues are not the same analysis as the reclassification of the bulk of the SBW. I do not find documented support for the assertions made that the NRC was in agreement with DOE's reclassification of the bulk of the SBW. Please advise me the specific documents I need to review.
The NRC review focused on the first criterion under the DOE Order 435.1 Waste Incidental to Reprocessing (WIR) process: “The waste must have been processed, or will be processed, to remove key radionuclides to the maximum extent that is technically and economically practical.” NRC concluded that it is not technically or economically practical to remove additional key radionuclides from the SBW prior to disposal; this conclusion applies to the bulk of the SBW and is not limited to residual materials. In the NRC’s recommendation for the first criterion they state, “residual uncertainty is not expected to … invalidate DOE-ID’s conclusion that SBW . . . can be managed as TRU waste.”
The other two criteria in DOE Order 435.1 WIR process pertain to waste classification and disposition requirements. The NRC did not explicitly evaluate these criteria—regarding classification of SBW as transuranic waste and disposal at the Waste Isolation Pilot Plant (WIPP)—because they determined that doing so would be inappropriate and outside NRC’s jurisdiction given that NRC’s WIR guidance does not include a TRU disposal option and the WIPP’s long-term performance is regulated by the Environmental Protection Agency.
At this time, DOE has not made a decision related to the final classification and disposition of the SBW.
Question: ICP Progress presentation for Feb 21 stated "CPP-749 Degradation." It is an underground fuel storage facility. I cannot find any information about the degradation and no information was provided to the ICP CAB. Can you please explain the degradation to the spent nuclear fuel storage facility?
Answer: The Underground Fuel Storage Facility, (UFSF), CPP-749, is located at the Idaho Nuclear Technology and Engineering Center (INTEC) within the Idaho National Laboratory site (INL). It is comprised of two engineered fuel storage areas referred to as the first generation (1st gen) and second generation (2nd gen) vaults. The 1st gen vaults were placed into operation in September of 1971, and the 2nd gen vaults were placed into operation in December of 1984.
Despite the careful engineering inherent in the design of the 1st gen vaults, small amounts of water have been observed within these vaults. The water gained access through either seepage or condensation. While the fuel is containerized, it is not desirable to have fuel stored with water over the long term. This can result in hydrogen generation and structural degradation. As a result, fuel contained within the 1st gen vaults will be transferred to the more robust 2nd gen vaults where water has never been observed. Phase 1 activities (sampling, HEPA venting, and preparation of a cost estimate) are complete. Phase 2 (fuel transfers) will begin when funds are secured.
The degradation issue was discussed during a Citizens Advisory Board meeting in Sun Valley in October, 2018. After that meeting, we also received a question from a member of the public and responded with the following answer, which has also been posted immediately below:
Question from October 2018: Are the problems at CPP-749 related to the fire water leak that caused some flooding of the wells many years ago?
Answer from October 2018: Not directly. We’d been aware of degradation in the CPP-749 wells for some time prior to the fire water leak. In 1997, our contractor made five fuel transfers out of the CPP-749 dry wells to begin dealing with the situation. When we received authorization to construct a spent fuel packaging facility, fuel transfers were put on hold to avoid handling the fuel more than necessary. However, the spent fuel packaging facility was later cancelled. We are now in the process of addressing the problem by improving the ventilation of the dry wells, and making plans to eventually remove the fuel from the first generation vaults where the problem is focused.
October 25, 2018
The following question was asked by a member of the public during the ICP CAB's October 25, 2018 meeting in Sun Valley, Idaho. The answer to the question is provided by DOE-ID staff.
Are the problems at CPP-749 related to the fire water leak that caused some flooding of the wells many years ago?
Answer: Not directly. We’d been aware of degradation in the CPP-749 wells for some time prior to the fire water leak. In 1997, our contractor made five fuel transfers out of the CPP-749 dry wells to begin dealing with the situation. When we received authorization to construct a spent fuel packaging facility, fuel transfers were put on hold to avoid handling the fuel more than necessary. However, the spent fuel packaging facility was later cancelled. We are now in the process of addressing the problem by improving the ventilation of the dry wells, and making plans to eventually remove the fuel from the first generation vaults where the problem is focused.
February 21, 2018
The following questions were submitted via question cards by a member of the public during the ICP CAB's February 21, 2018 meeting in Idaho Falls. Answers to the questions are provided by DOE-ID staff.
Has DOE decided not to ship ATR fuel elements to the Savannah River Site?
Answer: DOE signed a Record of Decision in the mid-1990s to consolidate fuels with similar cladding at specific sites. DOE has not decided to fully implement this decision at this time.
Where did the INTEC aquifer disposal wells connect to the INTEC SNF reprocessing facility?
Answer: The well was located next to CPP-666. It was used to dispose of service wastewater, which consisted primarily of plant cooling water, demineralizer and boiler blowdown water, and condensates from the Process Equipment Waste Evaporator (PEWE). The well was fed from the PEWE building. It was used from 1950 to 1984, and was officially closed in 1989.
Will the CAB be told comprehensively what seismic fragility studies have been conducted for the calcine storage facilities?
Answer: DOE is prepared to provide the CAB with information about what studies have been done on calcine storage facilities if requested.
Why isn’t the DOE study of ways to keep AMWTP – a continuing mission(s) – made public and put on the ICP CAB web site ASAP?
Answer: The DOE analysis of AMWTP continuing mission is not complete. DOE is refining its analyses to assess the challenges, cost-effectiveness and viability of a continuing mission for AMWTP.
Does DOE or the State DEQ know what fraction of the carbon tetrachloride in air in Idaho Falls is from INL/ICP?
Answer: INL/ICP carbon tetrachloride releases to air are well below levels that require ambient air monitoring at the INL Site, Idaho Falls, or other locations.