It's a big job ...
INL's Idaho Cleanup Project is not for the meek
By PAUL MENSER
Since 1988, the U.S. Department of Energy has been using milestones to keep track of the cleanup at Idaho National Laboratory.
The date is significant. It was only in 1989 that the DOE agreed it was subject to state and federal oversight.
After that, there was a lot of catching up to do, with many facilities from the '50s and '60s way out of compliance with two laws -- the Resource Conservation and Recovery Act and the Comprehensive Environmental Response, Compensation and Liability Act (better known as the Superfund law).
There were limited options, said Kliss McNeel, director of environmental and regulatory services for the Idaho Cleanup Project.
"We had to look at retrofitting, and where we couldn't do that, we started talking about closure," she said.
The maze of regulations, voluntary consent orders work plans can get convoluted very quickly. Still, in nearly 20 years, the DOE has missed only four of the 708 milestones it has been obligated to meet at INL.
Today, it is fair to say that after years of fits and starts, cleanup is well under way at INL.
Since May 2005, when the seven-year, $2.9-billion Idaho Cleanup Project contract went into effect, 140 milestones have been met.
The contractor, CWI, has until 2012 to clean up the remnants of the old site. Its managers are confident of getting the biggest cleanup tasks finished, and so is the client, the DOE.
"The work force is really dedicated toward getting the mission done and getting it done safely," said Beth Sellers, manager of the DOE-Idaho site.
The biggest tasks include emptying 900,000 gallons of high-level sodium-bearing waste in tanks at the Idaho Nuclear Technology and Engineering Center, formerly known as the Idaho Chemical Processing Plant, and grouting them. The waste itself will be refined into a solid material using the Integrated Waste Treatment Unit, a $461 million facility scheduled to open in 2009.
"That project is really the centerpiece of the entire cleanup project," ICP spokesman Joe Campbell said.
Using a steam reformation process, the plant will be the first of its kind in the DOE complex. It is bound to be of high interest to the DOE, which has problems with liquid waste on a much larger scale at its Hanford and Savannah River sites.
"The rest of the department will be watching what happens here very closely," Sellers said.
Cleanup moving ahead
Considering how long it took to get started, cleanup has been moving at a brisk pace since 2005.
The Loss of Fluid Test Reactor and the 50-year-old Experimental Test Reactor have both been removed and disposed of. Aside from the Specific Manufacturing Capability project, where tank armor is manufactured for the Army, much of Test Area North is now little more than a pile of dirt.
With ETR out of the way, this year, demolition and decontamination work on the Material Test Reactor (the second oldest reactor at the site) and the Power Burst Facility is due to pick up.
But one thing Idaho Cleanup Project people are discovering, however, is that taking apart a 50-year-old reactor can be as arduous as building it, perhaps more so.
When it came time to take down the ETR, "You couldn't trust the drawings," said Chuck Landgraver, a longtime site employee who worked on many of the reactors he is now helping to dismantle.
Engineers are in the habit of tweaking things to suit a particular experiment's purposes, so what you have at the end is a much different animal than what the drawings show, he said.
They are also learning that there is far more lead in the old reactor buildings than they anticipated. Landgraver said they were expecting to find 300,000 pounds. They ended up removing 1 million pounds, shipping it to Energy Solutions' landfill for hazardous waste in Utah.
The Materials Test Reactor, built in 1952, is proving to be no different. There are large blocks of lead in the concrete floor, and the vessel itself is grouted in at the bottom and top.
While taking out old buildings and facilities, there's also the issue of keeping the heat and lights on for the neighbors.
Next door to the Materials Test Reactor, Battelle Energy Alliance is busy with the Advanced Test Reactor, which it regards as its crown jewel for nuclear testing and research. As a result, cleanup workers and engineers have to take special precautions so they're not disrupting Battelle's work while they do their own.
Across the road from the Reactor Technology Complex, at INTEC, CWI-WG is working hard to close two landmark fuel reprocessing facilities from the 1950s, CPP-601 and CPP-640.
Although the radioactive materials have been flushed from the cells, CPP-601 contains miles of asbestos covered piping and tons of tanks, lead and concrete.
The ICP contract calls for it to be readied for demolition by 2012. If it is ready before then, CWI-WG will look to DOE for guidance, said Joe Campbell, spokesman for the contractor.
But what could be the Idaho site's most nettlesome cleanup issue is the Subsurface Disposal Area at the Radioactive Waste Management Complex.
At the Advanced Mixed Waste Treatment Facility, contractor Bechtel BWXT takes care of the waste that has been stored above ground since 1970. It has been beating its deadlines since 2005, and expects by May this year to have shipped one-third of the 65,000 cubic meters of waste due to be shipped to the Waste Isolation Pilot Plant in New Mexico by 2018 at the latest.
Next door, however, a few hundred feet above the East Snake Plain Aquifer, sits a 35-acre maze of unlined pits and trenches dating back to 1952, filled with barrels and boxes of plutonium-contaminated rags, clothes and tools, sludge contaminated with radioactive material and organic solvents.
In the '50s and '60s, it was where the Atomic Energy Commission sent waste from not only the National Reactor Testing Station (as INL was known at that time), but from other AEC operations, such as the Rocky Flats Plant in Colorado, where plutonium triggers for hydrogen bombs were made.
Going by the records engineers have examined and the sampling they've done under the Accelerated Retrieval Project, the Rocky Flats waste is concentrated in specific areas of the Subsurface Disposal Area.
Looking for a particular barrel or box in the records, "We've been as close as five feet and never more than 20 feet away," said Steve Lopez, ICP's field manager at the Subsurface Disposal Area.
There was one instance in which, going by the records on hand, they were able to pinpoint the location of a truck tailgate that had been dumped.
All the forensic examination of records and sampling has gone into a computer system that visualizes where the waste is.
The central question is, "What's the maximum amount of waste we can take out of here and achieve our goals?" Lopez said.
Nevertheless, different parties might define their goals differently.
The DOE proposed in a draft plan, released in October, that focused on excavating 4.8 acres, believing they pose the greatest risk. Overall, there is buried waste in 35 acres. A final decision is expected this spring.
The main concern is not necessarily removal of all waste, but the prevention of its release into the environment. The cost of the project is estimated at $734 million, with work extending over 18 years.
Besides radioactive waste, there is more than a million pounds of organic waste intermixed with the material that came from Rocky Flats. In the eyes of the cleanup engineers, this poses a much greater threat to the aquifer than plutonium.
Using vapor vacuum extraction units, ICP has removed and destroyed more than 220,000 pounds of organics in the buried waste using an oxidation process similar to what goes on in the catalytic converter of a car.
Campbell said the vapor vacuum extraction units have been very effective at destroying much of the organics and limiting their ability to migrate toward the aquifer.
Along with vapor extraction and excavation, the DOE's plan also involves capping the area to keep rain and snow from percolating through the ground.
While some might hold that every last bit of waste must be removed, Peter Strauss of San Francisco, the Snake River Alliance's point man on the issue, is not necessarily one of them.
Under a technical assistance grant from the EPA, Strauss was hired last fall to study the plan and comment on it.
Although he has concerns about how long-term monitoring will be handled, Strauss said he was impressed by a lot of what DOE was proposing.
"In general, when I read the proposed plan, I was surprised by the amount of money and commitment DOE was willing to spend on this remedial action," he said.
Regardless of what the final plan looks like, 2.8 acres of the Subsurface Disposal Area are slated to be cleaned up by 2012 under CWI's contract. Some waste from the pits and trenches has already been packed at the Advanced Mixed Waste Treatment Plant and shipped to New Mexico for permanent disposal. If the 4.8 acre proposal is adopted, those 2.8 acres will be part of that total.
The work goes on in the face of a legal dispute between the DOE and the state of Idaho.
The state has a May 2006 decision from U.S. District Judge Edward Lodge, who said the 1995 Settlement Agreement -- which was between Idaho, the Navy and the DOE -- applies to all transuranic waste at INL, whether it's buried or above ground.
DOE has argued that the 1995 agreement applies only to above-ground waste, and that the buried waste is addressed by a 1991 CERCLA cleanup agreement between DOE, the state of Idaho and the EPA, which designated the site as a Superfund cleanup project.
Lodge ruled the 1995 agreement wasn't worded that way, that it simply said "all," estimating the quantity at 65,000 cubic meters.
"It seems only reasonable that if the federal government intended the agreement to be restricted to the transuranic waste above ground, it would have said so," he said. "The words 'all transuranic waste now located at INEL' are all-inclusive terms and unambiguous."
As far apart as their positions might seem, state and DOE officials say they'd like to negotiate a settlement before the decision on a cleanup plan comes out, probably in May.
"There could be an effort between the state and the DOE to resolve this," said Curt Fransen, deputy director of the Idaho Department of Environmental Quality. "There haven't been any meetings, but there have been overtures. It needs to happen in the next two or three months."
No other state has an agreement as comprehensive as Idaho's 1995 Settlement Agreement, but there are major questions, such as what happens if Battelle wants to bring spent fuel in for testing, or what happens if Idaho stands to be selected as a reprocessing site for the Global Nuclear Energy Partnership.
Lastly, high-level waste, like the calcined material at INTEC, still doesn't have any place to go. While low-level and transuranic waste can be shipped to WIPP by 2018, the Yucca Mountain Repository in Nevada remains in political limbo.
Campbell said he expects a solution eventually.
"WIPP faced all sorts of delays, yet it's taking waste now," he said. "Our job is to have waste ready to go, and that's what we're focusing on."
Cleanup is well under way at
Idaho National Laboratory, where waste contains hazardous
chemicals and radioactive
Hazardous/mixed waste: The Environmental Protection Agency defines hazardous waste as "by-products of society that can pose a substantial or potential hazard to human health or the environment when improperly managed." These can be ignitable, corrosive, reactive or toxic, but they are not radioactive. Mixed waste is a combination of hazardous and radioactive wastes. For example, liquid high-level waste, the byproduct of spent fuel reprocessing, can be a combination of hazardous chemicals and radioactive elements.
High-level waste: This is the highly radioactive material resulting from processing of spent nuclear fuel. (Processing stopped in the United States since 1977, due to proliferation concerns. Some other countries continue to process nuclear fuel.) Reprocessing spent nuclear fuel at Idaho National Laboratory involved dissolving spent fuel in acid and then chemically extracting the uranium, leaving behind liquid that was very acidic, highly radioactive and full of chemicals qualifying it as hazardous waste. (Because it is hazardous and radioactive, it also qualifies as mixed waste.)
Calcined waste: Using a facility called a calciner, much of the liquid high-level waste at INL was refined at high temperatures into a solid material resembling laundry detergent. This was then stored in stainless steel vats. The second calcining plant was closed in 2000. Nevertheless, making liquid waste into a solid is a goal of the environmental management plan at INL and a requirement of the 1995 Settlement Agreement. Construction is scheduled to start this year on a steam-reforming plant at the INTEC tank farm, which will treat 900,000 gallons of sodium-bearing high-level waste. (There are people who say that if the calciner had been kept in operation for another year, all liquid high-level waste at the tank farm could have been rendered into a more stable solid form.)
Spent nuclear fuel: It consists of used-up fuel rods from nuclear reactors. These rods no longer have what it takes to efficiently work in a reactor. But they generally have 95 percent of the uranium left in them, which reprocessing proponents argue is going to waste.
Transuranic waste: Resembling industrial trash -- tools, gloves, protective garb, soil, sludge, etc. -- transuranic waste is nevertheless contaminated by elements such as plutonium and other byproducts of a nuclear reaction. Most transuranic waste was created during the production of nuclear weapons. At the Radioactive Waste Management Complex, INL has one of the world's largest deposits of transuranic waste. Ninety-five percent of it came from the Department of Energy's now defunct site at Rocky Flats, Colo., where plutonium triggers for hydrogen bombs were manufactured.
Low-level waste: It's any radioactive waste that is not spent fuel, high-level waste or transuranic waste.
The Settlement Agreement
PARTIES: The Department of Energy, the U.S. Navy, the state of Idaho
REACHED: October 1995
BASIS: A lawsuit filed by the state to prevent shipments of spent nuclear fuel to Idaho National Laboratory for storage.
BACKGROUND: The state's INL Oversight Program estimated there were 261 metric tons of heavy metal from spent fuel, 65,000 cubic meters of stored transuranic waste, another 62,000 cubic meters of buried transuranic waste, approximately 2 million gallons of high-level liquid waste and 3,700 cubic meters of calcined (dried liquid) waste already stored at Idaho National Laboratory when Gov. Phil Batt took office in January 1996. Until the Settlement Agreement, there was no legally binding commitment to remove any of this waste from Idaho.
Idaho will allow a total of 1,135 shipments of spent fuel to come to INL for interim storage over a 40-year period. Of those shipments, 575 will come from the Navy. The rest will come from other DOE sites, foreign research reactors (if the DOE chooses to accept that fuel), university reactors and a small amount from private companies directly supporting DOE research and development activities.
The DOE will remove all spent nuclear fuel from Idaho no later than 2035.
The DOE will treat all high-level waste at INL, in preparation for final disposal elsewhere.
All transuranic waste will be removed from the state by a target date of Dec. 31, 2015, and no later than Dec. 31, 2018.
All spent fuel will be placed in dry storage by Dec. 31, 2023, and such facilities will be placed, if technically feasible, at a point not above the East Snake Plain Aquifer.
PENALTIES: If the DOE fails to remove all spent fuel by 2035, the state may levy a fine of $60,000 per day. If the DOE fails to meet any of the agreement milestones at any point, the state may ask the federal court to halt any further spent fuel shipments to INL.
What's at issue
with the Subsurface Disposal Area?
The U.S. 9th Circuit Court of Appeals is scheduled to hear sometime this spring the Department of Energy's appeal of Federal Judge Edward Lodge's ruling that buried waste on 35 acres at the Radioactive Waste Management Complex is governed by the 1995 Settlement Agreement. As such, it must be removed from Idaho by 2035.
The DOE has held that the 1995 agreement covers only the waste stored above ground on asphalt pads at RWMC, and that buried waste is governed by CERCLA regulations and the 1991 Federal Facilities Act and Consent Order.
Lodge said there were no such distinctions made in the 1995 Settlement Agreement.
Cleanup work at site is governed by two acts of Congress
While the 1995 Settlement Agreement has the force of a court order, cleanup work at the Department of Energy-Idaho site is governed by two acts of Congress, RCRA and CERCLA. These "compliance drivers" are regulatory in nature.
The Resource Conservation and Recovery Act was enacted in 1976 as an amendment to the Solid Waste Disposal Act of 1965. It authorizes the Environmental Protection Agency to regulate waste management activities. If states decide to develop and enforce programs consistent with or stricter than the federal program, under RCRA they have that option.
The Comprehensive Environmental Response, Compensation and Liability Act was enacted in 1980 in response to the Love Canal disaster. Better known as the Superfund law, it was created to protect people from heavily contaminated toxic waste sites that had been abandoned, paying for cleanup at sites where no other responsible parties could pay with money collected on petroleum and chemical companies.
Federal Facilities Act/Consent Order (1991)
An agreement between the EPA, the DOE and Idaho Department of Environmental Quality, this lays out the terms and conditions and an action plan for environmental assessments and cleanup of places known to have contaminated groundwater in the past. At INL, these include injection wells at Test Area North and the Idaho Chemical Processing Plant and the Subsurface Disposal Area at the Radioactive Waste Management Complex. It requires unanimous agreement of the three parties or completion of dispute resolution.
Notice of Noncompliance Consent Order (1992)
An agreement between the DOE and the Idaho Department of Environmental Quality, this resolved a 1989 EPA site RCRA inspection that found problems with the configuration of stored transuranic waste at the RWMC and high-level liquid waste at the Chem Plant's Tank Farm.
INEEL Site Treatment Plan (1995)
An agreement between the DOE and Idaho Department of Environmental Quality, this governs treatment and disposal of mixed low-level waste, transuranic waste and limited high-level waste. It allows for updates at quarterly meetings and annual revisions that involve pubic comment.
Voluntary Consent Order (2000)
An agreement between the DOE and the Idaho Department of Environmental Quality, this governs the closure of self-disclosed RCRA issues.
The people involved
Idaho Cleanup Project
Average age: 48.32 yrs
Ph.D. degrees: 17
Master's degrees: 220
Bachelor's degrees: 444
Average length of INL
service: 15.32 years