R. Mitchell - S. M. Stoller Corporation
M. Lewis, D. Frederick, B. Beus, B. Andersen, and M. Verdoorn - Battelle Energy
Alliance
One potential pathway for exposure (primarily to workers) to contaminants released from the Idaho National Laboratory (INL) Site is through the water pathway (surface water, drinking water, and groundwater). INL Site contractors monitor liquid effluents, drinking water, groundwater, and storm water runoff to comply with applicable laws and regulations, U.S. Department of Energy orders, and other requirements (e.g., Wastewater Land Application Permit [WLAP] requirements). The Naval Reactors Facility conducts their own WLAP equivalent and drinking water monitoring.
During 2005, liquid effluent and groundwater monitoring was conducted in support of WLAP requirements for INL Site facilities that generate liquid waste streams covered under WLAP rules. The WLAPs generally require compliance with Idaho groundwater quality standards in specified groundwater monitoring wells. The permits specify annual discharge volume and 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 monitored in liquid effluent in support of surveillance activities.
Aluminum, iron, and manganese concentrations in unfiltered samples from both aquifer and perched water wells associated with the Idaho Nuclear Technology and Engineering Center (INTEC) New Percolation Ponds WLAP have exceeded the associated groundwater quality standards in the past. These high concentrations were detected in unfiltered preoperational groundwater samples taken from a downgradient aquifer well (ICPP‑MON‑A‑166) and the upgradient aquifer well outside the zone of influence of the INTEC New Percolation Ponds (ICPP‑MON‑A‑167) and have persisted since the INTEC New Percolation Ponds began receiving wastewater. For aquifer wells, the preoperational concentrations in the upgradient well (ICPP-MON-A-167) are considered the natural background level (IDAPA 58.01.11.200.03) and are used for determining compliance with the permit and the Ground Water Quality Rule. Because concentrations of these metals in aquifer wells during 2005 were below the preoperational upgradient concentrations, they are considered in compliance with the permit and the Ground Water Quality Rule.
The January and February 2005 monthly total suspended solids (TSS) concentration in the Test Area North (TAN)/Technical Support Facility Sewage Treatment Facility effluent exceeded the permit limit of 100 mg/L. It was suspected that the sanitary drain line from the former TAN-609 building was inadvertently filled with debris (gravel, silt, sediment) when the building was demolished in 2003, and then in late 2004, when trailers were moved into the area and placed on-line with the sanitary system, the effluent from restrooms began driving silt and sediment downgradient. Concentrations of TSS in the monthly samples returned to normal levels (below 20 mg/L) after the sediment traps and drain lines were cleaned, and remained well below the permit limit for the remainder of the year.
During 2005, 545 routine samples and 65 quality control samples were collected and analyzed from INL Site facilities. In 2005, total coliform bacteria was detected at the Main Gate, EBR-I, and Gun Range. In the Radioactive Waste Management Complex public water system, carbon tetrachloride remained below the U.S. Environmental Protection Agency (EPA) established maximum contaminant levels (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 3.50 μg/L. The annual average for the production well was 5.18 μg/L. Trichloroethylene concentrations in samples from the TAN drinking water Well #2 remained below the MCL of 5 μg/L during 2005.
The estimated annual effective dose equivalent to a worker from consuming all their drinking water at the Central Facilities Area during 2005 was 0.50 mrem/year (5.0 μSv/year). The EPA standard for public drinking water systems is 4 mrem/year.
No storm water monitoring was conducted in 2005. A technical analysis was finalized that identified projects that had no reasonable potential to discharge to waters of the United States, and inspection and reporting for these activities ceased.
This chapter presents results from radiological and nonradiological analyses of liquid effluent, groundwater, drinking water, and storm water samples taken at onsite locations. Results from sampling conducted by the INL and Idaho Cleanup Project (ICP) contractors are 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 for ingestion of water).
Sections 5.1 and 5.2 describe liquid effluent and groundwater monitoring as required by the City of Idaho Falls and Idaho Wastewater Land Application Permits (WLAP), and effluent monitoring that is done for surveillance activities only. The INL Site drinking water programs are discussed in Section 5.3. Section 5.4 describes storm water monitoring, while Section 5.5 summarizes onsite waste management water surveillance activities.
Table 5-1 presents the various water-related monitoring activities performed on and around the INL Site.
The INL contractor and the ICP contractor monitor nonradioactive and radioactive parameters in liquid waste effluent and groundwater. Wastewater (nonradioactive) 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 WLAP rules (Idaho Administrative Procedures Act [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 INL Site facilities that generate liquid waste streams covered under WLAP rules. Table 5-2 lists the current WLAP 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, application rates, and effluent quality limits. As required, an annual report is prepared and submitted to the Idaho Department of Environmental Quality (DEQ).
During 2005, the contractors conducted monitoring as required by the permits for each of the first four facilities listed in Table 5-2. The RTC 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 Orders 5400.5 and 450.1 (DOE 1993, DOE 2003) environmental protection objectives. Section 5.3 discusses the results of liquid effluent surveillance monitoring.
Description – The City of Idaho Falls is authorized by the Clean Water Act, National Pollutant Discharge Elimination System, to set pretreatment standards for nondomestic wastewater discharges to publicly owned treatment works. The INL contractor and U.S. Department of Energy-Idaho Operations Office (DOE-ID) 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 INL 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 INL Research Center has specific monitoring requirements.
Wastewater Monitoring Results – Semiannual monitoring was conducted at the INL Research Center in April and October of 2005. Table 5-3 summarizes the 2005 semiannual monitoring results.
Description – The CFA Sewage Treatment Plant serves all major
facilities at CFA. It is southeast of CFA, approximately 671 m (2200 ft)
downgradient of the nearest drinking water well.
A 1500 L/minute (400 gal/minute) 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 46 MG (23 acre‑in./acre/year) from April 1
through October 31.
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 2005. Effluent samples were collected from the pump pit (prior to the pivot irrigation system) starting in June 2005 and continuing through September 2005 (the period of irrigation operation for 2005). All samples collected were flow proportional composites, except pH and coliform samples, which were collected as grab samples. Table 5-4 and Table 5-5 summarize the results.
Wastewater was applied via the center pivot irrigation system on 53 days between June 2, 2005, and September 29, 2005. On the days it was operational, discharge to the pivot irrigation system ranged from 596,138 to 789,173 L/day (157,500-208,500 gal/day) and averaged 695,305 L/day (183,686 gal/day).
The total volume of applied wastewater for 2005 was approximately 9.94 MG (4.98 acre-in./acre/year), which is significantly less than the permit limit of 46 MG (23.0 acre-in./acre/year). Hydraulic loading was highest in June and lowest in September. Nitrogen loading rates were significantly lower at 2.59 kg/ha/year (2.31 lb/acre/year) than the projected maximum loading rate of 35.8 kg/ha/year (32 lb/acre/year). 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 35.8 kg/ha/year [32 lb/acre/year]) (CES 1993). The extremely low 2005 nitrogen loading rate had a negligible effect on nitrogen accumulation.
The 2005 annual total chemical oxygen demand (COD) loading rate at the CFA Sewage Treatment Plant 48.27 kg/ha/year (43.09 lb/acre/year) was substantially less than state guidelines of 20,443 kg/ha/year (18,250 lb/acre/year).
The annual total phosphorus loading rate of 0.87 kg/ha/year (0.78 lb/acre/year) was markedly below the projected maximum loading rate of 5.0 kg/ha/year (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 and TSS achieved the projected efficiency of 80 percent, and COD was below the projected efficiency of 70 percent. During the 2005 permit year, the average REs indicate that treatment in the lagoons was sufficient to produce a good quality effluent for land application.
WLAP Groundwater Monitoring Results – The WLAP does not require groundwater monitoring at the CFA Sewage Treatment Plant.
Description – The INTEC Sewage Treatment Plant (STP) is east of
INTEC, outside the INTEC security fence. It treats and disposes of sanitary and
other related waste at INTEC.
The sewage system consists of seven lift stations, which pump 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-000130-04, the INTEC STP consists of:
Because the STP depends on natural biological and physical processes (digestion, oxidation, photosynthesis, respiration, aeration, and evaporation) to treat the wastewater, the five control stations are used to direct the wastewater flow to the proper sequence of lagoons. After treatment in the lagoons, the effluent is then gravity fed to lift station CPP-2714 where it is pumped to the service waste system at manhole MAH‑PHE‑SW-106. For the STP, automatic flow-proportional composite samplers are located at control stations CPP-769 (influent) and CPP-773 (wastewater effluent from the STP to the service waste system). These composite samplers are connected to flow meters, thus allowing flow‑proportional samples to be taken.
WLAP Wastewater Monitoring Results – 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 wastewater 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 5-6, Table 5-7, and Table 5-8. All samples are collected as 24‑hour flow‑proportional composites, except pH and total coliform, which are taken as grab samples as required by the permit.
WLAP Groundwater Monitoring Results –To measure potential impacts to groundwater from the INTEC New Percolation Ponds, the permit requires that groundwater samples be collected from six monitoring wells (Figure 5-1):
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. Aquifer well ICPP-MON-A-167 and perched water well ICPP-MON-V-191 are listed in the permit as upgradient, noncompliance points. Contaminant concentrations in the compliance wells are limited by PCS and SCS specified in IDAPA 58.01.11, “Ground Water Quality Rule.” All permit‑required samples are collected as unfiltered samples.
Table 5-9 shows the April and October 2005 water table elevations and depth to water table, determined before purging and sampling, and the analytical results for all parameters specified by the permit for aquifer wells. Table 5-10 presents similar information for the perched water wells.
Aquifer well ICPP-MON-A-167 was dry during the October 2005 sampling. This is the first time this well could not be sampled because of insufficient volume. Since October 2002, when WLAP sampling began, the depth of water in this well has ranged from approximately 150.9 m (495 ft) to just less than 152.4 m (500 ft). In March 2004, routine maintenance was performed on this well and a new pump was installed. However, in April 2004, when samplers tried to obtain the permit-required sample, the new pump was inoperable and had to be replaced before taking the sample on April 7, 2005. In October 2005, when samplers tried to obtain the October permit-required sample, the water level had fallen below the intake of the pump, and a compliance sample could not be obtained. The pump is currently positioned near the bottom of this well and cannot be lowered farther. Unless the water level rises above the pump intake, future WLAP samples cannot be collected from this well. Similarly, water levels in wells ICPP‑MON‑A‑165 and ICPP-MON-A-166 have also been dropping (see Figure 5-2). All three aquifer wells will continue to be monitored semiannually, and analytical samples will be taken if sufficient water exists.
Perched water well ICPP‑MON-V-191 was dry during both the April and October 2005 sampling events. The well is not expected to have sufficient volume to sample during the required April and October compliance periods unless there is extended flow in the Big Lost River to sufficiently recharge the perched water at this well. During 2005, there was flow in the river in the vicinity of the INTEC New Percolation Ponds for a 10-day period starting on May 31, 2005. Before then, the river had been dry since May 2000. While well ICPP-MON-V-191 did receive recharge from this event, insufficient volume existed in the well to obtain a sample.
Groundwater Quality Standard Exceedances Summary — Metals. Aluminum and iron concentrations in unfiltered samples taken from perched water well ICPP‑MON‑V‑200 in April 2005 (McNeel 2005a) and iron concentrations in October 2005 (McNeel 2006b) exceeded the associated groundwater quality standards. Aluminum, iron, and manganese concentrations in unfiltered samples from both aquifer and perched water wells associated with the INTEC New Percolation Ponds WLAP have exceeded the associated groundwater quality standards in the past. These high concentrations were detected in unfiltered preoperational groundwater samples taken from a downgradient aquifer well (ICPP‑MON‑A‑166) and the upgradient aquifer well outside the zone of influence of the INTEC New Percolation Ponds (ICPP‑MON‑A‑167) and have persisted since the INTEC New Percolation Ponds began receiving wastewater. For aquifer wells, the preoperational concentrations in the upgradient well (ICPP-MON-A-167) are considered the natural background level (IDAPA 58.01.11.200.03) and are used for determining compliance with the permit and the Ground Water Quality Rule. Because concentrations of these metals in aquifer wells during 2005 were below the preoperational upgradient concentrations, they are considered in compliance with the permit and the Ground Water Quality Rule.
Perched water well ICPP-MON-V-200 was first sampled in October 2002. Concentrations of aluminum and iron in the unfiltered samples from ICPP-MON-V-200 were first detected above SCSs in April 2003. During 2005, concentrations of both aluminum and iron in the unfiltered samples remained above the SCSs.
Because of persistently high concentrations of these metals in unfiltered samples taken from both aquifer and perched water wells, several investigative and corrective actions have been taken. A study by Hull, Wright, and Street (2004) was conducted prior to the October 2004 permit‑required sampling. The specific objectives of this investigation were to determine the source of suspended solids in the wells and to evaluate the relationship between the suspended solids and metals concentrations that exceed groundwater quality standards.
The study generally concluded that elevated concentrations of aluminum, iron,
and manganese are directly attributable to undissolved, suspended solids in
unfiltered groundwater samples. Composed mainly of quartz and alumino-silicate
minerals, the solids may have originated from washed-in interbed material
derived from the completion zones of the wells (from sedimentary interbeds or
from sediment-infilled fractures). 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). Such sediment, present as suspended solids in
water samples, would result in high unfiltered concentrations of common elements
in rock-forming minerals, particularly iron, aluminum, and manganese (Gibs et
al. 2000). When the samples are filtered through a 0.45 μm filter, the metals
concentrations fall below the respective groundwater quality standards.
Review of Effluent Concentrations. 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 concentrations of these metals
in the effluent are significantly lower than the concentrations in the three
wells addressed in their study and are below the respective SCSs. Average permit
year concentrations of these metals are summarized in Table 5-11.
Groundwater Quality Standard Exceedances Summary — TDS. The concentration of TDS in well ICPP‑MON‑V-200 in October 2005 (503 mg/L) exceeded the SCS of 500 mg/L (McNeel 2006c). The concentrations of TDS, as well as chloride and sodium, in the perched water continue to be influenced by the concentrations of these parameters in the wastewater (CPP-797 effluent) discharged to the INTEC New Percolation Ponds (Figure 5-3), with little attenuation of these three parameters by the soil. A Salt Loading Corrective Action Plan and Schedule was submitted to DEQ and is currently being revised. Once approved and implemented, the planned corrective actions are intended to reduce salt loadings to the INTEC New Percolation Ponds.
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; before that, treated wastewater was disposed of through an injection well (TSF-05). The TAN/TSF Disposal Pond (TAN-740) consists of a primary disposal area and an overflow section, both of which are located within an unlined, fenced 14-ha (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 0.4 ha (0.9 acres) and 0.13 ha (0.330 acres), respectively, for a combined area of approximately 0.5 ha (1.23 acres). 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 waste from restrooms, sinks, and showers. The sanitary wastewater goes to the TAN‑623 Sewage Treatment Plant, 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; steam condensate; fire water discharges; and cooling; heating, and air conditioning water. The process wastewater is transported directly to the TAN-655 lift station, where it is combined with sanitary wastewater before being pumped to the TAN/TSF Disposal Pond.
WLAP Wastewater Monitoring Results – Total effluent to the TAN/TSF Disposal Pond for calendar year 2005 was approximately 44.7 million L (11.82 million gal).
The permit for the TAN/TSF Sewage Treatment Facility sets concentration limits for TSS and total nitrogen (measured at the effluent to the TAN/TSF Disposal Pond) and requires that the effluent be sampled and analyzed monthly for specific parameters. During 2005, 24-hour composite samples (except pH, fecal coliform, and total coliform, which were grab samples) were collected from the TAN-655 lift station effluent monthly.
Table 5-12 summarizes the effluent monitoring results for calendar year 2005. Monthly concentrations of TSS were below the permit limit (100 mg/L) with the exception of the January 2005 and February 2005 samples, which had a concentration of 248 and 103, respectively. It was suspected that the sanitary drain line from the former TAN-609 building was inadvertently filled with debris (gravel, silt, sediment) when the building was demolished in 2003, and then in late 2004, when trailers were moved into the area and placed on-line with the sanitary system, the effluent from the restrooms began driving silt and sediment downgradient. Concentrations of TSS in the monthly samples returned to normal levels (below 20 mg/L) after the sediment traps and drain lines were cleaned, and remained well below the permit limit for the remainder of the year. All monthly total nitrogen (total Kjeldahl nitrogen + nitrate+nitrite, as nitrogen) concentrations were below the permit limit of 20 mg/L, with the maximum monthly concentration of 10.1 mg/L reported in January 2005.
WLAP Groundwater Monitoring Results – To measure potential TAN/TSF Disposal Pond impacts to groundwater, the permit requires that groundwater samples be collected from five monitoring wells (Figure 5-4):
Sampling must be conducted semiannually and must include specified parameters for analysis. As specified in Section F of the permit, parameter concentrations in wells TAN-10A (except for iron), TAN‑13A, and TANT-MON-A-002 are limited to the PCSs and SCSs in IDAPA 58.01.11, “Ground Water Quality Rule.” Section F of WLAP LA-000153-02 exempted the iron concentrations in well TAN-10A from the limits set forth in IDAPA 58.01.11.200.01.b. All permit‑required samples are collected as unfiltered samples.
During the 2005 permit year, groundwater samples were collected in April and
October. Table 5-13 shows water table elevations
and depth to water table, determined before purging and sampling, and analytical
results for all parameters specified by the permit. Well TSFAG-05 was dry during
both April and October. Therefore, no analytical results are presented for this
well.
Iron concentrations in well TAN-10A were above the SCS of 0.3 mg/L in April 2005
and October 2005. Elevated iron concentrations historically have been detected
in the TAN WLAP monitoring wells. Because of increased iron concentrations in
all four of the TAN WLAP monitoring wells in 1999, a corrosion evaluation (CORRPRO 2000)
was performed at the TAN wells, and exhibited similar increases. This evaluation
confirmed that the riser pipes at several TAN wells were significantly corroded.
The riser pipes attached to the dedicated submersible pumps were replaced with
stainless steel riser pipes in all four TAN WLAP monitoring wells during August
2001. Video log information gathered during the well maintenance showed that the
stainless steel well casings in wells TAN-13A, TANT-MON-A-001, and
TANT-MON-A-002 appeared relatively free of rust to the water table. While some
residual effect of the well maintenance activities continued in 2002, iron
concentrations have decreased in all three of these wells based on samples
collected before the maintenance and those collected after the maintenance.
The April 2001 video log information gathered on well TAN-10A showed that the carbon steel well casing appeared corroded most of the way to the water table, with 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. Both total and dissolved iron concentrations in well TAN-10A increased immediately after the 2001 well maintenance was performed. While total iron concentrations have since dropped, concentrations of dissolved iron have continued to increase, and concentrations of both have consistently remained above the SCS.
Item No. 1 of Compliance Activity CA-153-07 requires a groundwater investigation of the iron concentrations in the TAN/TSF STF area. The conclusions of that investigation show elevated total (unfiltered) iron in many area wells, increased concentrations of dissolved (filtered) iron in area wells impacted by ongoing remediation activities, and impacts of the carbon steel casing in TAN-10A on the total (unfiltered) iron concentrations in that well (ICP 2006a). However, the investigation did not find that the elevated iron concentrations in TAN-10A were derived from iron discharged to the TSF Disposal Pond from the TAN/TSF STF effluent. The majority of the iron in well TAN-10A is dissolved iron, rather than solid phase iron, and the investigation did find that the increases in dissolved iron were correlated to the onset of in situ bioremediation operations in 1999. In situ bioremediation is being used to remediate the known trichloroethylene (TCE) hot spot that resulted from historical injections into injection well TSF-05.
However, because Section F of WLAP LA-000153-02 exempted the iron concentrations in well TAN-10A from the limits set forth in IDAPA 58.01.11.200.01.b, these exceedances do not represent permit noncompliances. Concentrations of both manganese and TDS in well TAN‑10A also exceeded their SCSs (0.05 mg/L and 500 mg/L, respectively) during the permit year. None of the groundwater samples taken from the other permitted wells exceeded parameter concentrations during the 2005 permit year.
For well TAN-10A, concentrations of both manganese and TDS have periodically been above their SCSs. The peak TDS concentration occurred shortly after riser pipe replacement, and the condition of the well casing may still be contributing to the TDS concentrations in well TAN-10A. Figure 5-5 shows the historical TDS concentrations in the effluent and in well TAN-10A. While increases in well TAN-10A in early 2000 seem to follow earlier increases in the effluent, no pattern is visibly evident from 2000 forward, with increases in well TAN‑10A occurring before increases in the effluent. Similarly, no visible pattern is evident for the concentrations of manganese in the effluent when compared to concentrations in well TAN-10A. Concentrations of TDS and manganese in well TAN-10A were also compared to available data from area wells located outside the hot spot of the TCE plume and wells outside the influence of the Disposal Pond, and reported concentrations of TDS and manganese were within the same concentration range as other area wells (ICP 2006b). ICP 2006b also found that concentrations of TDS and manganese in wells located within the vicinity of the TSF-05 injection well have increased as a result of the frequent amendment injections associated with the in situ bioremediation operations of the TCE hot spot, but were unable to determine if similar increases in TAN-10A were directly related to these activities.
The TAN/TSF WLAP requires semiannual monitoring of five wells in the vicinity of the TAN/TSF for a specific set of parameters. As specified in Section F of the WLAP, parameter concentrations in wells TAN-10A (except for iron), TAN-13A, and TANT-MON-A-002 are limited to the PCSs and SCSs. Concentrations of TDS (507 mg/L in April and 511 mg/L in October) and manganese (0.474 mg/L in April and 0.467 mg/L in October) in well TAN‑10A exceeded the SCSs of 500 mg/L and 0.03 mg/L, respectively (McNeel 2005a and McNeel 2006c). Before 2005, the concentrations of these parameters in well TAN-10A first exceeded their respective SCSs in October 2004.
The peak TDS concentration occurred shortly after riser pipe replacement, and the condition of the well casing may still be contributing to the TDS concentrations in well TAN-10A. The periodic elevated concentrations in well TAN-10A of both TDS and manganese were investigated (ICP 2006b). The conclusions of that investigation were:
Concentrations of TDS and manganese in well TAN-10A, as well as other permitted wells, will continue to be monitored semiannually.
Description – The RTC 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 (ATR) 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 (RTC‑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 (Total Kjeldahl Nitrogen + nitrogen, nitrite + nitrate) and TSS 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 5.2.
Automated samplers are used to collect quarterly 24-hour time-proportional composite samples from TRA-764. TSS and total nitrogen results are summarized in Table 5-14. For 2005, all TSS 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 2005 was 3.812 mg/L, which was also significantly less then the regulatory limit of 20 mg/L.
WLAP Groundwater Monitoring Results – Currently, there are no groundwater monitoring requirements associated with the RTC Cold Waste Pond. However, groundwater monitoring is expected to be required when a permit is issued.
As stated in Section 5.1, additional radiological and nonradiological parameters specified in the Idaho groundwater quality standards also are monitored. The following sections discuss results of this additional monitoring by individual facility. This additional monitoring is performed to comply with DOE Orders 450.1 and 5400.5 environmental protection objectives.
Both the influent and effluent to the CFA Sewage Treatment Plant are monitored according to the WLAP issued for the plant. Table 5-15 summarizes the additional monitoring conducted during 2005 at the CFA Sewage Treatment Plant and shows those parameters which were detected in at least one sample during the year. Additional monitoring is performed quarterly from the floor drains and vehicle maintenance areas of the Transportation Complex at CFA‑696. During 2005, most additional parameters were within historical concentration levels.
A WLAP is in effect for the INTEC New Percolation Ponds. Table 5-16 summarizes the additional monitoring conducted during 2005 at INTEC and shows the analytical results for parameters which were detected in at least one sample during the year.
During 2005, most additional parameters were within historical concentration levels.
During 2005, the Industrial Waste Pond, Industrial Waste Ditch, and Secondary Sanitary Lagoon were sampled monthly for iron, sodium, chloride, fluoride, sulfate, pH, conductivity, TSS, turbidity, biological oxygen demand, gross alpha, gross beta, gamma spectrometry, and tritium. Additionally, a sample for selected metals is collected once a year, and the Secondary Sanitary Lagoon is sampled monthly for total coliform. The Secondary Sanitary Lagoon was not sampled in January, and the Industrial Waste Pond was dry for part of the year and was only sampled in March through August. Table 5-17, Table 5-18, andTable 5-19 summarize the analytical results for parameters which were detected in at least one sample.
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, iodine-129, and tritium, which are monitored annually, and strontium-90, which was monitored monthly starting in March 2005). Table 5-20 summarizes the results of this additional monitoring for those parameters which were detected in at least one sample during the year.
During 2005, the concentrations of most additional parameters were within historical concentration levels.
The effluent to the Cold Waste Pond receives a combination of process water from various RTC facilities. Additional monitoring for surveillance purposes is conducted quarterly for metals and for radiological parameters. Table 5-21 summarizes the results of this additional monitoring for those parameters which were detected in at least one sample during the year.
The largest volume of wastewater received by the RTC Cold Waste Pond is secondary cooling water from the ATR when it is in operation. During 2005, concentrations of sulfate and TDS were elevated in samples collected during reactor operation. These differences are caused by 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 RTC 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.
In accordance with the “Idaho Rules for Public Drinking Water Systems” (IDAPA 58.01.08), INL Site drinking water systems are classified as either nontransient or transient, noncommunity water systems. The INL 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 INL 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 spell out MCLs). The federal Safe Drinking Water Act also establishes requirements for the Drinking Water Program.
Because groundwater supplies the drinking water at the INL Site, information on groundwater quality was used to help develop the Drinking Water Program. The U.S. Geological Survey and the various contractors monitor and characterize groundwater quality at the INL Site. Three groundwater contaminants have impacted INL 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 parts 141–143. State regulations also require the use of laboratories that either are certified by the state or by another state whose certification is recognized by Idaho. The DEQ oversees the certification program and maintains a listing of approved laboratories.
Currently, the INL contractor Drinking Water Program monitors 12 onsite water systems, which include 19 wells. Drinking water parameters are regulated by the state of Idaho under authority of the Safe Drinking Water Act. Parameters with primary maximum contaminant levels must be monitored at least once during every three-year compliance period. Parameters with secondary maximum contaminant levels are monitored every three years based on a recommendation by the EPA. The three‑year compliance periods for the INL contractor Drinking Water Program are 2005 to 2007, 2008 to 2010 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 INL 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 2005, total coliform bacteria was detected in the EBR-I, Gun Range, and Main Gate water systems.
During 2005, 545 routine samples and 65 quality control samples were collected and analyzed from CFA, EBR-I, Gun Range (Live Fire Test Range), INTEC, Main Gate, Materials and Fuels Complex (MFC), Critical Infrastructure Test Range Complex (CITRC), RWMC, TAN/Contained Test Facility (CTF), TAN/TSF, and RTC. In addition to the routine sampling, the INL contractor 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. Twenty-four requests for nonroutine sampling were received during 2005.
Analytical results of interest (carbon tetrachloride, trichloroethylene, and tritium) and nitrate (required to be monitored annually) results for 2005 are presented in Table 5-22 and Table 5-23, respectively, and are discussed in the following subsections. EBR-I, Gun Range, INTEC, Main Gate, CITRC, and TAN/CTF were markedly below drinking water limits for all regulatory parameters; therefore, they are not discussed further in this report.
In 2005, total coliform bacteria was detected at the Main Gate, EBR-I, and Gun Range water system. In the RWMC public water system, carbon tetrachloride remained below the EPA established 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 3.50 μg/L. The annual average for the production well was 5.18 μg/L. TCE concentrations in samples from the TAN drinking water Well #2 remained below the MCL of 5 μg/L during 2005.
In 2005, total coliform bacteria were detected in the EBR-I, Gun Range and Main Gate water systems.
The EBR-I Historical site is only open from Memorial Day through Labor Day. Bacteria were detected at EBR-I during testing of the system prior to opening. This was likely the result of stagnant water in the distribution system. The water distribution system was flushed and retested on May 5, 2005, and no further bacteria were detected.
Bacteria were detected at the Gun Range water system when the water
chlorination system was being repaired. After the chlorination system was back
on-line no further bacteria were detected.
The bacteria detected at the Main Gate water system were found when the filters
were plugged with sand. The filters were changed and no further bacteria were
detected.
Central Facilities Area – The CFA water system serves approximately 900 people daily. Since the early 1950s, wastewater containing tritium was disposed of to the Snake River Plain Aquifer (SRPA) at INTEC, and at RTC through injection wells and infiltration ponds. This wastewater migrated south‑southwest and is the suspected source of tritium contamination in the CFA water supply wells. This practice of disposing of wastewater through injection wells was discontinued in the mid-1980s.
In 2005, water samples were collected once from CFA #1 Well (at CFA-651), and quarterly from CFA-1603 (manifold) for compliance purposes. Since December 1991, the mean tritium concentration has been below the 20,000 pCi/L MCL at all three locations. In general, tritium concentrations in groundwater have been decreasing (see Figure 5-6) 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 Eastern SRPA, 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 2005 calculation was based on reported tritium and iodine-129 concentrations for the CFA distribution system.
For the 2005 dose calculation, it was assumed 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 2005 was 0.50 mrem/year (5.0 μSv/year). The EPA standard for public drinking water systems is 4 mrem/year.
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 (see Figure 5-7). 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 applies to the distribution system. The distribution system is the point from which water is first consumed and is the compliance point. Table 5-24 summarizes the carbon tetrachloride concentrations at the RWMC drinking water well and distribution system for 2005. The mean concentration at the well for 2005 was 5.18 μg/L, and the maximum concentration was 5.6 μg/L. The mean concentration at the distribution system was 3.50 μg/L, and the maximum concentration was 3.80 μg/L.
A potential source of the carbon tetrachloride is the estimated 334,630 L (88,400 gal) of organic chemical waste (including carbon tetrachloride, TCE, 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 2700 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. Vapor vacuum extraction has been used since January 1996 to help mitigate the organic compound contamination.
Permanent chlorination was installed in 2003 because of a history of total
coliform bacteria detection. Since permanent chlorination was installed, no
coliform bacteria have been detected.
Test Area North/Technical Support Facility – In 1987, TCE was detected at both
TSF #1 and #2 Wells, which supply drinking water to approximately 200 employees
at TSF. 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 5-8 illustrates the concentrations of trichloroethylene in both TSF wells and the distribution system from 2000 through 2005. Past distribution system sample exceedances are attributed to preventive maintenance activities interrupting operation of the sparger system.
Table 5-25 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 2005 because it was not required by the regulations. The mean concentration of trichloroethylene at the distribution system for 2005 was 1.08 μg/L, which is below the MCL.
The EPA National Pollutant Discharge Elimination System (NPDES) regulations for the point-source discharges of storm water to waters of the United States require permits for discharges from industrial activities (40 Code of Federal Regulations [CFR] 122.26 2003). Following these regulations, waters of the United States at the INL Site have been defined as the
Together, the above locations comprise the Big Lost River System.
A Storm Water Monitoring Program was implemented in 1993 when storm water permits initially applied to the INL Site 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 INL 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 2001) 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 hours 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 Idaho injection well permits. In 1997, responsibility for monitoring of storm water entering deep injection wells was transferred from the U.S. Geological Survey to the INL Site 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 2003, EPA Region 10 determined that three sites at the INL Site (RWMC, INTEC, and the North part of the INL Site 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 result of this determination, construction and industrial storm water inspections, data collection and reports have ceased for projects located at these facilities.
The remaining projects were evaluated through a technical analysis to determine any other areas under the INL Site’s control that would also have the same or less potential to discharge storm water to waters of the United States. 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 a preliminary technical analysis (finalized in early 2005), ceased.
In compliance with DOE Order 435.1, the ICP contractor collects surface water, as surface runoff, at the RWMC Subsurface Disposal Area (SDA) from the location shown in Figure 5-9. 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.
Surface water runoff samples were collected at the RWMC/SDA during the first and second quarters of 2005. Table 5-26 summarizes the results of human-made radionuclides. All sample results were comparable to historical concentrations.
40 CFR 122.26, 2006, “Storm Water Discharges,” Code of Federal Regulations, Office of the Federal Register.
40 CFR 141, 2006, “National Primary Drinking Water Regulations,” Code of Federal Regulations, Office of the Federal Register.
40 CFR 142, 2006, “National Primary Drinking Water Regulations Implementation,” Code of Federal Regulations, Office of the Federal Register.
40 CFR 143, 2006, “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.
Ansley, S.L., CWI, to T.R. Meachum, CWI, October 13, 2005,
“Spreadsheets with PW and CFA Landfill Data.”
Cascade Earth Science (CES), 1993, Soil Suitability Investigation for Land
Application of Waste Water, Central Facility Area, Idaho National Engineering
Laboratory, July 8, 1993.
CORRPRO Companies, 2000, Observation Well Pipe Evaluation at Test Area North, January 2000.
DEQ, 1995, “Wastewater Land Application Permit No. La-000115-02 for ICPP Sewage Treatment Plant.”
Forbes, J.R., CWI, to T.R. Meachum, CWI, November 9, 2005, “INTEC Metals Data.”
Gibs, J., Z. Szabo, T. Ivahnenko, and F.D. Wilde, 2000, “Change in Field Turbidity and Trace Element Concentration during Well Purging,” Ground Water, v. 38 (4), 577-588.
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.
ICP, 2006a, Analysis of INTEC Well Water Sediments, INL/EXT-06-01132, January 2006.
ICP, 2006b, Test Area North/Technical Support Facility Sewage Treatment Facility Wastewater Land Application Permit, Evaluation of Elevated Total Dissolved Solids and Manganese in Monitoring Well TAN-10A, ICP/EXT-05-01115, January 2006.
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.
IDAPA 58.01.08, “Idaho Rules for Public Drinking Water Systems,” Idaho Administrative Procedures Act, State of Idaho Department of Environmental Quality, 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.
Mann, L.J., 1996, Quality-Assurance Plan and Field Methods for Quality-of-Water Activities, U.S. Geological Survey, Idaho National Engineering Laboratory, Idaho, U.S. Geological Survey Open-File Report 96-615, DOE/ID-22132.
McNeel, K., CWI, to G. Eager, DEQ, August 8, 2006a, “State Water Self-Disclosure Log,” CCN 300672.
McNeel, K., CWI, to G. Eager, DEQ, January 31, 2006b, “December State Water Self-Disclosure Log,” CCN 302123.
McNeel, K., CWI, to G. Eager, DEQ, February 28, 2006c, “January State Water Self-Disclosure Log,” CCN 302123.
Rackow, T.A., DEQ, to M.G. Lewis, INEEL, October 6, 2004, “Comments on the Draft White Paper ‘INTEC New Percolation Ponds Wells ICPP-MON-A-166, ICPP-MON-A-167, and ICPP-MON-V-200’ (ICP/EXT-04-00575), discussing possible groundwater quality violations, Wastewater Land Application Permit LA-000130-03,” CCN 52800.
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.
U.S. Department of Energy-Idaho Operations Office (DOE-ID), 2001, Idaho National Engineering and Environmental Laboratory Storm Water Pollution Prevention Plan for Industrial Activities, DOE/ID-10431, Rev. 41, January.