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Naval Reactors Facility

ENVIRONMENTAL

SUMMARY

REPORT

September 2022

Prepared for the U.S. Department of Energy

By Fluor Marine Propulsion, LLC

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NRF Environmental Summary Report

iii

NAVAL REACTORS FACILITY

ENVIRONMENTAL SUMMARY REPORT

September 2022

Prepared For The U.S. Department Of Energy By

Fluor Marine Propulsion, LLC

Naval Reactors Facility

Idaho Falls, Idaho

Document Number: NRF-OSQ-ESH-01354

NRF Environmental Summary Report

TABLE OF CONTENTS

Page

TABLE OF CONTENTS ..................................................................................................................iv

LIST OF FIGURES ......................................................................................................................... v

LIST OF TABLES ............................................................................................................................ v

LIST OF ACRONYMS .....................................................................................................................vi

1.0 SUMMARY AND CONCLUSIONS ....................................................................................... 1

1.1 Background ........................................................................................................................... 1

1.2 Purpose................................................................................................................................. 1

1.3 Conclusions .......................................................................................................................... 1

2.0 NAVAL REACTORS FACILITY ........................................................................................... 3

2.1 NRF Site History .............................................................................................................. 3

2.2 Significant Accomplishments ........................................................................................... 3

3.0 DESCRIPTION OF NRF ...................................................................................................... 5

3.1 NRF Development ........................................................................................................... 5

3.2 Land Use and Demography ............................................................................................. 5

3.3 Geology and Seismology ................................................................................................. 6

3.4 Hydrology ........................................................................................................................ 9

3.4.1 Surface and Ground Water Sources ............................................................................ 9

3.4.2 Surface and Ground Water Use ................................................................................... 9

4.0 DESCRIPTION OF OPERATIONS .................................................................................... 11

4.1 Past Operations ............................................................................................................. 11

4.2 Present Operations ........................................................................................................ 13

5.0 WASTE GENERATION AND CONTROLS ........................................................................ 19

5.1 Current Waste Management Programs.......................................................................... 19

5.1.1 Radioactive Waste Management ............................................................................... 19

5.1.2 Non-Radioactive Waste Management ........................................................................ 20

5.1.3 Remediation Programs .............................................................................................. 22

5.2 Past Waste Management Practices ............................................................................... 23

5.2.1 Past Radioactive Waste Management ....................................................................... 23

5.2.2 Residual Radioactivity................................................................................................ 25

5.2.3 Past Non-Radioactive Waste Management ................................................................ 27

5.2.4 Groundwater Monitoring ............................................................................................ 28

6.0 MONITORING PROGRAMS ............................................................................................. 31

7.0 ASSESSMENT OF ENVIRONMENTAL IMPACTS ............................................................ 33

7.1 Remedial Action Areas .................................................................................................. 34

7.2 No Action Sites .............................................................................................................. 37

7.3 No Further Action Sites .................................................................................................. 37

NRF Environmental Summary Report

8.0 AUDITS AND REVIEWS ................................................................................................... 39

9.0 REGULATORY MATTERS ................................................................................................ 43

10.0 REFERENCES .................................................................................................................. 47

LIST OF FIGURES

Figure

Number Title Page

Figure 1 Relation of NRF to the INL ................................................................................... 7

Figure 2 NRF Site Area Plot Plan....................................................................................... 8

Figure 3 NRF Waste Area Group 8 .................................................................................. 35

LIST OF TABLES

Table

Number Title Page

Table 1 NRF Waste Area Group 8 Sites ......................................................................... 36

Table 2 Environmental Inspections/Visits of the NRF Site............................................... 40

NRF Environmental Summary Report

LIST OF ACRONYMS

A1W Large Ship Reactor Prototype

CAA Clean Air Act

CFR Code of Federal Regulations

CWA Clean Water Act

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act

COCA Consent Order and Compliance Agreement

D&D Decontamination and Decommissioning

DOE Department of Energy

DOE-EM Department of Energy – Environmental Management

DOP Dioctylphthalate

ECF Expended Core Facility

EPCRA Emergency Planning and Community Right-to-Know Act

EPA Environmental Protection Agency

FFA/CO Federal Facility Agreement and Consent Order

FFCA Federal Facility Compliance Act

FIFRA Federal Insecticide, Fungicide, and Rodenticide Act

HAP Hazardous Air Pollutant

HEPA High Efficiency Particulate Air

IDEQ Idaho Department of Environmental Quality

INL Idaho National Laboratory

IPDES Idaho Pollutant Discharge Elimination System

IWD Industrial Waste Ditch

LDR Land Disposal Restrictions

mrem millirem

mrem/hr millirem per hour

NEPA National Environmental Policy Act

NNPP Naval Nuclear Propulsion Program

NPL National Priorities List

NRF Naval Reactors Facility

PCBs Polychlorinated Biphenyls

RCRA Resource Conservation and Recovery Act

RI/FS Remedial Investigation and Feasibility Study

ROD Record of Decision

RWDS Radioactive Waste Disposal System

RWMC Radioactive Waste Management Complex

S1W Subsequent name for the Submarine Thermal Reactor Prototype

NRF Environmental Summary Report

vii

List of Acronyms (Cont.)

S5G Advanced Water Cooled Natural Circulation Submarine Prototype

SARA Superfund Amendments and Reauthorization Act

SDWA Safe Drinking Water Act

SRPA Snake River Plain Aquifer

TSCA Toxic Substances Control Act

USGS United States Geological Survey

UST Underground Storage Tank

WERF Waste Experimental Reduction Facility

NRF Environmental Summary Report

1.0 SUMMARY AND CONCLUSIONS

The Idaho National Laboratory (INL), which includes the Naval Reactors Facility (NRF or Site), is

owned by the United States Department of Energy (DOE) and the Naval Nuclear Propulsion Program

(NNPP). NRF has been operated for the NNPP by the Naval Nuclear Laboratory since the inception

of NRF in 1949. In 2016, the NNPP began using “Naval Nuclear Laboratory” to refer to the collective

operations of the four DOE sites that perform NNPP work and the personnel operating at the

associated locations. NRF is located on approximately 4,400 acres of land within the 572,200 acres

of the INL, 54 miles west of Idaho Falls, Idaho. NRF provides the NNPP with unique capabilities for

research and development of advanced naval nuclear propulsion plants.

1.1 Background

For many years, NRF and INL subcontractors have conducted environmental monitoring to

demonstrate that NRF is being operated in accordance with environmental standards. The results

have been published in the NRF and INL annual reports provided to federal, state, and local officials.

These publicly available reports demonstrate that NRF monitoring practices meet and are often

stricter than the requirements of applicable laws and regulations. The monitoring results confirm

compliance with environmental standards.

1.2 Purpose

While the annual reports describe monitoring practices and results, they do not describe the nature

and environmental aspects of NRF work and facilities nor do they give a historical perspective of the

Site's operations. The purpose of this report is to provide this information as well as background

information, such as the geologic and hydrologic nature of the NRF, pertinent to understanding the

environmental aspects of Site operations.

1.3 Conclusions

The following conclusions may be drawn from this report and the annual environmental monitoring

results:

NRF has had environmental control programs in place since critical operations began in 1953. The

objective of these programs has been to meet or exceed the requirements of laws and regulations

applicable at the time. NRF's performance in radioactivity control has established and maintained

levels of control that are equal to and in many cases more stringent than applicable requirements.

The maximum possible annual dose to a member of the public resulting from Site operations is

calculated by using conservative assumptions of release and human uptake. Such calculations show

that the dose is very small - approximately 0.00034 millirem (mrem) for 2017-2021. This is far less

than the approximately 366 mrem received by an average individual from natural background

radiation each year in southeastern Idaho, and is less than the approximate 3 mrem of additional

radiation exposure that an individual would receive from a single cross-country airplane flight.

There are isolated areas on the Site where controlled releases of low-level radioactive liquids were

made prior to 1979. The total radioactivity released to the soil over the operational life of NRF is

equal to the amount of naturally occurring radioactivity in the top 24 inches of native east central

Idaho soil covering a local area of equal size to NRF. Members of the public cannot come in direct

contact with any of the small amounts of residual radioactivity still present on the Site.

NRF Environmental Summary Report

Current NRF practices for handling chemical wastes conform with applicable federal and state

requirements, as confirmed by the Environmental Protection Agency (EPA) and the State of Idaho.

In the past, chemical waste disposal was carried out according to industrial practices common to the

time; some wastes were sent offsite for disposal and some chemicals were disposed of on the NRF

Site. Consequently, some chemical residues containing heavy metals such as chromium, lead and

silver are detectable in isolated areas of soil immediately adjacent to some of the chemical disposal

areas. Although hazardous contaminants have been detected in these areas, the levels involved

are below regulatory requirements and do not pose a threat to members of the public.

NRF operations have had no significant adverse effect on the groundwater of the Snake River Plain

Aquifer (SRPA). Monitoring results indicate radioactivity at or near natural background levels, and

no contaminants, solvents, or laboratory chemicals attributable to NRF operations above National

Primary Drinking Water Standards were detected. Low levels of sodium and chloride (as in table

salt) previously used to soften the Site’s water, and nitrates, possibly associated with historic

industrial sewage discharges, are detectable in the immediate vicinity of NRF, at levels below the

applicable primary drinking water standards.

Investigations of past disposal areas have been completed in accordance with the requirements of

the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). The

Hazard Ranking Score for the NRF Site was not high enough to warrant inclusion on the EPA

National Priorities List (NPL), also known as Superfund. Nonetheless, due to the higher Hazard

Ranking Scores of other facilities at the INL, the INL as a whole was placed on the NPL, and an

agreement (Federal Facility Agreement and Consent Order (FFA/CO)) was entered into by the EPA,

the State of Idaho, and the DOE by which the INL remedial activities will be completed under the

EPA and state supervision. A Comprehensive Remedial Investigation and Feasibility Study (RI/FS)

was completed in 1997. Based on this study, remedial actions were selected for nine sites at NRF.

The EPA and Idaho Department of Health and Welfare concurred with the selected remedial actions

in the Record of Decision (ROD) signed in September of 1998. Remedial action field work has been

completed.

NRF operations and environmental performance have always been subject to continuous oversight

by resident representatives of the NNPP, a joint Navy/DOE organization. Periodic in-depth reviews

and inspections are also conducted by personnel from NNPP headquarters.

In addition to NRF and NNPP reviews and inspections, NRF environmental programs are inspected

by the State of Idaho and the EPA in accordance with their regulatory authority. No violations from

these inspections were identified.

In conclusion, after decades of operation, NRF has had no significant impact on the environment or

adverse effect on the surrounding communities. NRF has a well-defined program in place to protect

the environment, to comply with state and federal environmental requirements and interagency

agreements, and to address remediation of the isolated residues from previous activities.

NRF Environmental Summary Report

2.0 NAVAL REACTORS FACILITY

NRF has been operated for the NNPP by the Naval Nuclear Laboratory since 1949. NRF is a

laboratory site where prototype naval nuclear propulsion plants were tested, Navy nuclear operators

were trained, and reactor components and naval spent fuel continue to be examined.

2.1 NRF Site History

The original mission of NRF was to demonstrate the feasibility of propelling submarines with nuclear

power. In August, 1950, construction began on the Submarine Thermal Reactor Mark I, the first

facility at NRF and prototype of the reactor that eventually propelled the first nuclear powered

submarine Nautilus (SSN 571). Initial operation of the Submarine Thermal Reactor (later named the

S1W Prototype) under nuclear power began on March 30, 1953. The S1W Prototype was used

throughout its life to test advanced design equipment and new systems for nuclear propulsion

projects and obtain data for future generations of nuclear propulsion plants. After more than 36

years of operation, the S1W Prototype was defueled in 1989 and systems were placed in layup in

1990.

Following the S1W Prototype nuclear propulsion plant, two other prototype nuclear propulsion plants

were constructed at NRF. The Large Ship Reactor Prototype (A1W Prototype), built in 1956,

demonstrated the feasibility of operating two reactor plants to power one propulsion shaft. The

concept was then used to power Enterprise (CVN 65), the Navy's first nuclear powered aircraft

carrier. The A1W Prototype continued to test new and advanced reactors for naval applications until

its shutdown in 1994. Defueling and systems layup work were completed in 1999.

The S5G Prototype, built in 1965, was designed to demonstrate the natural circulation concept for

reactor cooling ultimately used in the Narwhal (SSN 671) nuclear powered submarine. Similar to the

A1W Prototype, the S5G Prototype was shut down in 1995 and defueling and systems layup were

completed in 1999. The S1W, A1W, and S5G Prototypes served an additional major function as

training facilities for Navy nuclear propulsion plant operators.

NRF also houses the Expended Core Facility (ECF). Built in 1957 and substantially upgraded since

then, this examination facility was designed to handle and examine naval nuclear spent fuel and

reactor components as well as material and fuel samples irradiated in test reactors at other INL

facilities. The examinations of naval spent fuel performed at the ECF are critical to the design of

longer-lived reactor cores, which results in the creation of less spent fuel requiring disposition.

Programs at the ECF that examine materials exposed to a nuclear reactor environment have

provided a wealth of information for use in future naval nuclear propulsion plant designs. The ECF

has other related functions: maintenance and repair work on NNPP radioactive material shipping

containers and has the capability and equipment to load fuel modules into dry storage canisters for

eventual shipment out of the State of Idaho to a permanent repository.

2.2 Significant Accomplishments

The technologies developed within the Naval Nuclear Laboratory and tested at NRF are among the

most valuable and sensitive military technologies in the United States. They constitute a critical

element in the nation's defense system, making possible the extraordinary capabilities of the nuclear

powered submarines and surface ships that today comprise more than 40 percent of the Navy's

combatant fleet. The S1W plant proved, with its successful simulated non-stop, submerged, full

power, voyage from Newfoundland to Ireland in 1953 that reliable nuclear propulsion of submarines

was feasible. The A1W plant successfully demonstrated that the power necessary to propel a major

NRF Environmental Summary Report

surface vessel could be attained using propulsion trains, each powered by two reactors working

together. As nuclear technology advanced, the S5G Prototype, housing a natural circulation reactor,

was built to test a simpler and quieter reactor design. NRF continues to provide the NNPP with

unique capabilities for research and development of advanced naval nuclear propulsion plants.

NRF Environmental Summary Report

3.0 DESCRIPTION OF NRF

3.1 NRF Development

When the Naval Ordnance Plant was built in Pocatello, Idaho, in 1942, the federal government set

aside a large tract of desert land in the east central portion of Idaho. Designated the Naval Ordnance

Testing Range, this land supported the test firing of large naval guns. When the acreage was

transferred to the Atomic Energy Commission in 1949 it was renamed the National Reactor Testing

Station and subsequently became the INL. The INL is a dedicated remote site for energy research

and development, particularly for nuclear-related activities.

NRF was established in 1949, when a little over two acres of this testing station were cleared for the

Submarine Thermal Reactor (S1W Prototype). The location of NRF within the INL is shown in Figure

1. The developed portion of the NRF Site (Figure 2) is currently 89 acres in size. A major

construction project is underway on the east side of the NRF Site. This project is to construct a new

spent fuel handling facility. Once completed, this new facility will eventually replace most operations

within the ECF. The developed area of the NRF Site (Figure 2) will be updated when the project is

completed.

NRF includes decommissioned prototype nuclear propulsion plants (A1W, S1W, and S5G) and the

ECF. Supplemental buildings house administrative and training functions, mechanical refurbishment

and maintenance, boiler operations, temporary dry fuel storage, and warehouse functions.

Water for domestic purposes, fire protection, and landscape maintenance is supplied by several

wells. Electric power is supplied to the Site by the Idaho Power Company, Rocky Mountain Power,

and Montana Power Company. NRF also has its own sewage lagoon system on the northern

perimeter. Other support services required by NRF are supplied by activities on the INL Site.

3.2 Land Use and Demography

The NRF Site is located in Butte County. The INL also includes portions of Jefferson, Bingham, Clark,

and Bonneville counties.

The main population surrounding the INL lies to the east, along interstate highway I-15 and state

highway 91, which run generally north and south. The two largest cities (Pocatello and Idaho Falls)

are approximately 50 air miles from NRF. Most of the population is concentrated in communities to

the southeast: Pocatello and Idaho Falls each with a population of approximately 60,000; and

Blackfoot with 12,000. The entire area within a 50-mile radius of the INL contains a population of

approximately 176,000. This information is based on the 2020 census data.

Buses are available to transport workers to and from all Site facilities located within the INL boundary.

About 30 communities surrounding the INL provide personnel and services in support of INL

government projects. Small farming communities are located on the west central and northwestern

boundaries. Roughly 50 percent of the eastern boundary of the INL abuts agricultural land.

The INL is a major economic contributor to the southeastern Idaho economy. Several thousand

people are employed at the INL or as subcontractors, and much of the services and materials

consumed by INL activities are provided by local businesses.

NRF Environmental Summary Report

3.3 Geology and Seismology

The INL is located in the northeastern portion of the Snake River Plain. The Snake River Plain is a

U-shaped geologic feature approximately 300 miles long and 50 to 70 miles wide. Within its land

area of 12,000 square miles, the plain rises from an elevation of 2,300 feet in the west, near Boise,

to 6,000 feet in the east, near Ashton. The plain is bounded on all sides by mountains, some topping

12,000 feet.

The Eastern Snake River Plain extends southwesterly from the northeast corner of Idaho, near

Yellowstone National Park, toward the Hagerman-Twin Falls area. The Western Snake River Plain

extends northwesterly to the Idaho-Oregon border from the Hagerman-Twin Falls area.

The geological processes that produced the Snake River Plain are fairly recent by geologic

standards, taking place within the last 17 million years.

Reference 1 is an excellent source for data on the plain, a large geologic feature of basaltic lava

flows, which erupted from fissures and shield-type volcanoes. Although the geology of the basalt

appears simple, genesis of the plain, anomalies in geophysical data, and wide variations in

stratigraphy below the basalt reveal a complex geological system. Geological deposits in the Eastern

Snake River Plain consist of Recent to Pleistocene (within two million years) unconsolidated

windblown lake- and stream-deposited sediments overlying multiple layers of basalts and

interbedded sedimentary layers. The stream and lake bed sediments are comprised primarily of

sub-rounded to rounded gravels composed of all rock types represented in the adjacent mountains

as well as the local basalts. Deposition of this large quantity of gravelly material appears to have

resulted from sustained stream flows higher than currently exist, climatologically dating much of the

sedimentation to the late Pleistocene epoch.

Ten thousand feet of basalt layers interbedded with ancient stream and lake bed sediments dampen

or attenuate shock waves generated by earthquakes. Over the past 100 years, there have been

numerous earthquakes with a magnitude of 5.5 or greater with epicenters ranging from 58 to 176

miles from NRF (Reference 2). An earthquake with a magnitude of 7.5 on the Richter Scale hit the

west flank of the Madison Range some 116 miles northeast of NRF in August of 1959. The facilities

at the INL were shaken but not damaged. On October 28, 1983, an earthquake hit the west side of

the Lost River Range with a magnitude of 7.3 on the Richter Scale. This earthquake was 58 miles

west of NRF; again the Site felt the disturbance without sustaining damage. On March 31, 2020, a

6.5 magnitude earthquake occurred in Central Idaho, approximately 105 miles northwest of the Site.

The earthquake was felt on-site but no injuries or damage were recorded. Work on-site was

temporarily stopped while buildings and facilities were assessed for damage. No damage was

reported.

The geology of the NRF Site is similar to that of the Eastern Snake River Plain and consists of four

basic informal layers. The surface layer consists of wind deposited silts and clays interspersed with

fine sand. The next layer consists of alluvial deposits that range from clean gravels with few fines to

well graded gravels with a sandy matrix. The third layer occurs as discontinuous clays that fill

topographic depressions in the upper-most basalt flow. Finally, the last layer is composed of a thick

sequence of basalt flows interbedded with sedimentary layers.

NRF Environmental Summary Report

Figure 1- Relation of NRF to the INL

TO SALMON

TO DUBOIS

TO REXBURG

TO IDAHO FALLS

TO ARCO

HOWE

TO BLACKFOOT

IDAHO 33

SCALE IN MILES

0 5 10 15

NRF

Boise

INL

Pocatello

IDAHO NATIONAL

LABORATORY

(INL)

RELATION OF NRF

TO THE INL

Idaho

Falls

IDAHO

894 Square Miles

2315 Square Kilometers

AND POCATELLO

890 Square Miles

NRF Environmental Summary Report

Figure 2 – NRF Site Area Plot Plan

NRF Environmental Summary Report

3.4 Hydrology

3.4.1 Surface and Ground Water Sources

The closest natural surface water to NRF is the Big Lost River. This river bed lies 1.5 miles east of

NRF and is dry for periods ranging from six months to five years or more. The Little Lost River flows

towards the INL from the north and sinks into the ground near the INL border seven miles north of NRF.

Groundwater in the Eastern Snake River Plain is contained primarily in one major unit known as the

SRPA. The SRPA is a large groundwater resource estimated to contain more than 1 billion acre-feet

of water, with a flow rate of 2 to 26 feet per day (Reference 3). The general direction of flow in the

SRPA is from northeast to southwest. At NRF, groundwater flow is generally from north to south.

The amount of water the aquifer can produce at a given location ranges from several gallons to several

million gallons per day. This range in production rates is due to variability of geologic properties in the

aquifer. Recharge to the aquifer is provided by underflow from the northwest portion of the plain and

by rivers that drain upland areas to the north, notably the Big and Little Lost Rivers and Birch Creek.

3.4.2 Surface and Ground Water Use

The United States Geological Survey (USGS) has investigated the hydrology of the Eastern Snake

River Plain in and around the INL. The major demands for groundwater in or near the INL are

agricultural irrigation and INL facility use.

NRF has six production wells (two of these wells are not currently being used) that produce sufficient

water for normal operational needs plus added reserve capacity.

NRF Environmental Summary Report

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NRF Environmental Summary Report

4.0 DESCRIPTION OF OPERATIONS

4.1 Past Operations

Four major installations are located at NRF. These are the three prototypes (S1W, A1W, S5G) and

ECF.

S1W Prototype Plant. The Submarine Thermal Reactor, as S1W was first known, was the first

prototype of a submarine nuclear reactor and the first installation at NRF. To support work on the

nuclear reactor, a shielded cell, controlled water-shielded fuel handling area, and decontamination

facility were constructed within the prototype structure. Use of the support facilities was drastically

reduced in 1957, when the ECF was constructed with an improved capability for work on irradiated

core components.

The S1W Prototype Plant was in operation for 36 years. Extensive testing was performed on reactor

core components, including a series of experiments in 1955 for studying the effects of boiling

conditions in nuclear reactor plants. The tests, conducted according to preplanned procedures and

under carefully controlled conditions, yielded a large amount of core performance and survivability

data. In 1989, the S1W Prototype was shut down and all the fuel was removed.

A1W Prototype Plant. The A1W Prototype, constructed in 1958, had two nuclear reactor plants.

The A1W Prototype consists of a dual pressurized water reactor plant representing a portion of the

propulsion spaces of a large surface ship.

A1W was originally designed with two reactors used to supply steam to one propulsion plant. In

1967, the steam system was divided so that more independent operations could be conducted with

each reactor. This modification allowed either plant to operate for testing purposes while the other

plant was used for the training of Navy personnel, thus utilizing both reactors to their potential. In

1994, the A1W Prototype was shut down and all the fuel was removed.

S5G Prototype Plant. Construction of the S5G Prototype was initiated in 1961. This prototype was

a pressurized water reactor having the capability to operate in either a forced circulation or a natural

circulation flow mode, with cooling flow through the reactor generated by thermal circulation rather

than pumps. In 1995, the S5G Prototype was shut down and all the fuel was removed.

Expended Core Facility. Since 1957, the ECF has received, examined and prepared naval fuel

modules for shipment to the Idaho Nuclear Technology and Engineering Center at the INL.

Shipments to this facility ceased in 2001, and current fuel modules are prepared for dry storage. The

ECF also specializes in the handling and examination of irradiated material samples from the INL

Advanced Test Reactor. These small-scale representations of fuel and core component designs are

used to provide test information for design personnel. The tasks are accomplished in controlled

water-shielded work areas. After removal from sealed shipping containers, the small samples are

transferred into shielded cells for a more detailed examination.

The only non-naval fuel examined at the ECF has been the reactor cores removed from the

Shippingport Atomic Power Station, the nation's first civilian nuclear power station. In the mid-1950s,

the Atomic Energy Commission requested the NNPP to develop Shippingport. The Bettis Atomic

Power Laboratory was the prime contractor responsible for this design. In 1987, the ECF examined

the final Shippingport reactor core, the Light Water Breeder Reactor design, and provided

measurement data which demonstrated that a reactor core fueled by uranium-233 and thorium-232

could breed more fuel than was consumed during the life of the core.

NRF Environmental Summary Report

Cooling Towers and Spray Ponds. Two large spray ponds were built for cooling the S1W

Prototype, each with a capacity of 2,250,000 gallons. Both spray ponds have been removed.

The A1W and S5G Prototypes both had cooling towers used to dissipate the heat from the secondary

cooling system. During operations of these cooling systems, continuous blowdown of water at a rate

of a few gallons per minute was used to control concentrations of dissolved minerals naturally

present in the supply water. The blowdown water, which was not radioactive, was discharged into

the NRF Industrial Waste Ditch (IWD). The A1W cooling tower has been completely removed with

its concrete basin buried in its original location. The S5G cooling tower was dismantled except for

the concrete basin, which is used for the storage of emergency firefighting water.

Sewage Treatment Facilities. In 1951, a small sewage treatment plant was constructed consisting

of an Imhoff Tank, sludge drying beds (Figure 3, item NRF-21B), and an effluent drain field (Figure

3, item NRF-11). The drain field was used until 1955 for combined radioactive liquid effluent and

sewage effluent. In 1956, a sewage disposal basin (Figure 3, item NRF-21A) was constructed

southeast of NRF for sewage effluent. Radioactivity was inadvertently introduced into the disposal

basin in 1956. This sewage disposal basin was used until 1960 when the NRF sewage lagoons

(Figure 3, item NRF-23) were constructed on the north side of NRF.

The original sewage disposal basin and associated systems have been remediated as specified in

the NRF Final ROD signed by the EPA and State of Idaho in September of 1998 and as modified by

an Explanation of Significant Difference signed by the EPA and State of Idaho in 2002.

In 1972, the lagoons, constructed in 1960, were expanded to their maximum size. The sewage

lagoons were in operation until 2012 when a lined lagoon complex was constructed to meet the state

design standards for wastewater lagoons. In 2019, these old lagoons were filled in with clean soil

from the excavation associated with the project to construct a new spent fuel handling facility.

Leaching Beds. Prior to 1979, controlled releases of water containing low levels of radioactivity

were made to soil beds near the A1W and S1W Prototypes. The releases to these leaching beds

were made in accordance with standards applicable at the time, and no member of the general public

has ever received any measurable radiation exposure from the beds. The releases were

discontinued in 1979 when on-site facilities for recycling water containing trace amounts of

radioactivity became operational. The residual radioactivity remaining in the soil beds today cannot

be reached by members of the general public, as the areas have been capped and access is

controlled. Remedial actions were performed in these areas per the ROD.

Landfills. NRF maintained its own non-radioactive landfill operations until the early 1960s, when all

solid wastes began to be shipped to the landfill at the INL Central Facilities Area. These landfills

were typical for that era, containing garbage, construction debris, waste oil, solvents, scrap iron, and

asbestos. Most of the waste in the landfills was burned. The first NRF landfill was north of the S1W

Prototype. After this landfill was closed, a location on the west side of the facility and a large area

at the northeast corner of the facility were utilized for solid waste disposal.

During the time they were used, there were no local, state, or federal requirements governing such

operations. Remedial corrective actions for these have been completed in accordance with the INL

CERCLA FFA/CO. The remedial actions required that landfill covers be placed over the landfills and

monitored. The EPA and the State of Idaho oversaw these actions.

NRF Environmental Summary Report

The remedial actions implemented at NRF under the FFA/CO were used as an example of

successful application of CERCLA presumptive remedies by a December 1996 EPA directive

(Reference 4).

The initial CERCLA Five-Year Review for the remedial actions that were implemented for the inactive

landfill areas was completed in 2001. More recent Five-Year Reviews that provided updates for the

remedial actions implemented for the inactive landfill areas and remedial actions at other CERCLA

sites were completed in 2006, 2012, 2017, and 2022. All of these reviews, through the use of annual

inspections of the landfill covers placed over the inactive landfill areas and the ongoing review of

groundwater and soil gas monitoring data, concluded that the landfill covers continue to be effective

at containing contaminants by inhibiting infiltration of precipitation and by preventing direct contact

with contaminated soils and landfill wastes.

4.2 Present Operations

The NRF employs engineers, scientists, and support personnel for procedure preparation activities,

decontamination and demolition of obsolete facilities, and spent naval nuclear fuel and component

inspection and testing. The spent fuel program is supported by the NRF facilities described below.

Expended Core Facility. The ECF receives fuel removed from naval reactors for examination.

Since naval nuclear fuel is robust in nature and designed to meet the stringent operational

requirements for naval nuclear propulsion reactors in ships of war, the fuel maintains its integrity

indefinitely under the less demanding conditions encountered during storage. Measurements of the

corrosion rates for naval fuel designs have shown that naval spent nuclear fuel can be safely stored

indefinitely wet or dry with no adverse effects to the environment. In addition to spent fuel, the ECF

also receives irradiated materials testing specimens for examination.

The ECF is a single building about 1,000 feet long and 194 feet wide, with a 38-foot high bay running

the length of the building. The high bay contains 4 water pool work areas 20 to 45 feet deep designed

for safe underwater disassembly, examination, and analysis of radioactive components and

irradiation tests. The high bay area enclosing the water pools and servicing areas has four large

overhead cranes.

The water pools contain 3.2 million gallons of water, which is cooled to prevent algae growth and

enhance clarity. All this water is recirculated and filtered so no radioactive liquid is discharged to the

environment.

The ECF also contains several shielded cells for remote manipulation of radioactive materials. The

shielded cells are adjacent to the high bay area and are fully enclosed. These cells are maintained

at a negative air pressure with ventilation exhausted through charcoal and high efficiency particulate

air filters. The effluent downstream of the filters is monitored to confirm that emissions are very low.

The cells have been refurbished and updated to improve their working capacity.

Currently, construction of the new Naval Spent Fuel Handling Facility is underway. The facility will

be a 213,000 square foot, three-story structure to support operations involved in the management of

spent nuclear fuel prior to transfer to a permanent repository. The Naval Spent Fuel Handling Facility

will incorporate some of the capabilities that currently exist at the ECF and its support facilities as

well as additional capabilities for handling spent nuclear fuel received in newly designed shipping

containers. Future projects may also include other support buildings and infrastructure to increase

efficiency and effectiveness of managing spent nuclear fuel and to support operations at the Naval

Spent Fuel Handling Facility.

NRF Environmental Summary Report

All radioactive water generated at NRF is collected and processed through a filtration and ion

exchange system to remove particulate materials and reduce the radioactivity levels. The processed

water is then reused. The system filters and resin are disposed of as solid radioactive waste. All of

the essential processing facilities for liquid and solid waste are serviced by filtered and monitored

exhaust systems. All of the solid radioactive waste is disposed of in compliance with current

regulations

Spent Fuel Packaging Facility. The Spent Fuel Packaging Facility is presently capable of receiving

spent fuel directly from the ECF water pools. Baskets of spent fuel are loaded and seal welded into

Spent Fuel Canisters. These canisters are loaded into concrete shielded overpacks, and the loaded

overpacks are moved to a temporary dry storage facility.

The Spent Fuel Packaging Facility consists of three distinct facilities, the Overpack Construction and

Storage Facility, the Canal Dry Processing Facility, and the South End Extension. Pathways

between the facilities provide for movement of the overpacks using a combination of air pallets and

crawler transport vehicles.

Overpack Construction and Storage Facility. This facility contains an area equipped with a crane

and utilities necessary for constructing concrete shielded overpacks. Another portion of the facility

provides for temporary storage of loaded and unloaded overpacks.

Canal Dry Processing Facility. This facility is equipped with two cranes and receives spent fuel

directly from the ECF water pools and contains a loading station for placing the fuel into the canisters

and shielded overpacks. A canal connects this facility with the ECF water pools.

South End Extension Facility. This facility receives baskets of spent fuel transported from the

Canal Dry Processing Facility in a shielded container. The facility contains four stations located in a

single pit; two stations are for an inactive process and two are used for loading and sealing spent

fuel canisters and overpacks. The building contains a high bay with two overhead cranes.

Cask Shipping and Receiving Facility. In 2016, this facility began receiving shipping containers

loaded with canisters of spent naval fuel. The canisters were removed from the shipping container

and placed into concrete shielded overpacks that are temporarily stored in the Overpack Storage

Facility until a permanent off-site repository becomes available. The facility is a high bay structure

with two railcar bays, a pit with two ports for shipping container operations, and a single overhead

crane.

Chemistry Laboratories. NRF maintains a chemistry laboratory that performs chemical analyses,

radiochemistry, and isotopic identification. The chemistry lab is located at A1W for the support of

NRF operations, remediation work, ECF support, and environmental monitoring.

Boiler House. The first boiler house at NRF was located in S1W. A second boiler house was later

placed north of the machine shop. Both were replaced in 1958 by the existing boiler house located

north of the Administration Building. The boiler system included three diesel oil fired saturated steam

boilers (Boilers 1, 2 and 3) and all necessary auxiliaries. As of 2018, these boilers were removed

from service. NRF installed two new portable boilers, designated as Boiler 4, in late 2016 and Boiler

5 in 2017. These two new portable boilers are located to the south and to the west of the existing

boiler house. Steam is supplied to various Site buildings for heat. Fuel oil is trucked to the facility

and stored in two above ground 25,000-gallon storage tanks surrounded by concrete revetments.

NRF Environmental Summary Report

Craft Support Buildings. To support planned facility maintenance, NRF has a Site services craft

shop. This shop has a fully equipped machine shop capable of handling most facility components.

Also located within the shop are a pipe fitting area, welding booths, sheet metal shop, rigging loft,

mechanics area, carpenter shop, paint shop, and a locksmith shop.

Sewage Treatment Lagoons. In 2012, NRF began operation of a 21-acre, dual-cell, lined sanitary

sewer lagoon complex. These lagoons were installed to replace the existing clay lined lagoons that

had been in operation since the 1960s. This sanitary sewage lagoon complex is located northeast

of the previous lagoons.

Warehouses. There are several different warehouses on site. Some of these are used for spare

parts and general warehousing. Others are used for the storage of records, radioactively

contaminated components, or by subcontractor personnel. Warehouses containing radioactive

material are controlled as Radioactive Material Storage Areas.

Industrial Waste Ditch. The IWD, an evaporative-percolation type wastewater disposal system,

was used to channel non-hazardous, non-sewage wastewater from stormwater, snowmelt runoff,

and NRF operations. The IWD follows the course of two old stream beds that have been connected,

straightened, and deepened by dredging. The large uncovered portion of the IWD is 3 to 10 feet

wide, running approximately 3.2 miles in length. Because discharges to the IWD have decreased

dramatically with the shutdown of the three prototype plants and the associated support equipment,

water, 1 to 2 feet in depth, generally occupies only the first 300 yards of the uncovered portion of the

IWD.

Much of the IWD is located outside the developed area of the facility and supports a wide variety of

plant and animal life. Some portions of the ditch contained within the security fence include a

comprehensive network of underground pipes and small uncovered surface channels. The interior

network drains into a covered exterior culvert, a lift station, calming basin, a junction chamber, and

finally through an environmental monitoring station vault, then outfalls to an uncovered exterior

channel. The entire west main line of the interior underground system of the IWD was replaced in

2019. In addition, a majority of the north main line of the interior IWD was also replaced in 2022.

Investigations have been performed on the interior and exterior portions of the IWD. These

investigations were performed in accordance with the INL CERCLA FFA/CO. No remedial action

was determined to be necessary for these areas as documented in the NRF Industrial Waste Ditch

and Landfill Areas ROD.

In 2007, the IWD, which received industrial wastewater from site operations, was permitted as a

“reuse treatment system” by the Idaho Department of Environmental Quality (IDEQ). Prior to

issuing this Industrial Reuse Permit, no monitoring was required for this facility by regulatory

agencies. However, NRF has always monitored the IWD as a best management practice. This

permit required certain analytes to be monitored and it also stipulated the frequency they were to

be monitored.

In the fall of 2020, NRF completed the rerouting of industrial wastewater from the IWD to the non-

discharging, lined, evaporative sewage lagoons. On January 4, 2021, the IDEQ approved NRF’s

Industrial Reuse Permit Closure Plan and terminated the permit. This closure plan still allows the

operation of the IWD for storm water runoff, raw water, demineralized water, steam condensate,

chlorinated potable water, and heating/air conditioning condensate to be discharged. Now that the

IWD does not operate under a permit by the IDEQ, effluent sampling is not required at the IWD but

NRF Environmental Summary Report

will continue to be performed as a best management practice. NRF will continue to monitor

groundwater as required in the IDEQ approved Closure Plan.

Deep Wells and Drinking Water System. NRF has six deep wells that provide water for all

operations at NRF. Two of these wells are not currently being used. Five of the six wells are between

500 and 600 feet deep and one well is approximately 1,300 feet deep. Two wells (NRF-3 and NRF-

14) are used for drinking water. The other two working wells (NRF-1 and NRF-4) are used primarily

for Site production, lawn watering, and fire protection. One well (NRF-2) was used until 2006 for

drinking water, but is currently out of service with the intention that it could be returned to service in

the future if needed. The other well (NRF-5), which is out of service, is currently being used as an

observation well only.

Drinking water is monitored regularly and results from all samples were below the Idaho Rules for

Public Drinking Water Systems standards.

Fire Water Tank. A new 150,000 gallon fire water tank was recently constructed. This large tank is

needed to support NRF operations. Once commissioning of this tank is finalized, it will replace an

older smaller tank currently in use.

Demineralizer Facility. Many NRF operations require the use of demineralized water that is

processed from well water. Previously this process used large quantities of sulfuric acid and sodium

hydroxide for regeneration of the ion exchange resin used in the demineralizers. Prior to 1985, the

acid and basic reagent solutions were discharged directly to the IWD where the acid and basic

reagents self-neutralized in the channel. In 1985, a facility to neutralize these solutions and monitor

pH prior to discharge was put into operation, and direct discharge of demineralizer regeneration

solutions to the IWD was terminated. In 1997, a reverse osmosis water purification system was

installed, eliminating the need for ion exchange resin and the resulting regeneration solutions.

Hazardous Waste Management. Hazardous waste routinely generated at NRF is managed in

satellite accumulation areas in accordance with federal and state regulations. Once full, containers

are transferred to a Central Accumulation Area for less than 90-day storage. Hazardous wastes

stored in this less than 90-day area are manifested and shipped to an off-site EPA-permitted facility

for treatment or disposal by the INL.

Radioactive Waste Storage. NRF has temporary storage areas for the collection of radioactive

wastes. Until April 2021, NRF Remote-Handled Low-Level Waste was disposed at the INL

Radioactive Waste Management Complex (RWMC). The RWMC is an INL facility under the

cognizance of the DOE Idaho Operations Office. The RWMC has closed and no longer receives

radioactive waste shipments. The Remote-Handled Low-Level Waste Disposal Facility located on

the INL now accepts NRF Remote-Handled Low-Level Waste. All non-CERCLA contact handled

wastes are shipped to commercial facilities for recycling, volume reduction, or disposal.

Mixed Waste Storage. Mixed wastes generated at NRF are managed in satellite accumulation

areas in accordance with federal and state regulations. Full containers of mixed waste are placed

in a Central Accumulation Area for less than 90-day storage. Mixed wastes are manifested and

shipped to an off-site EPA-permitted facility for treatment or disposal through the INL.

S1W Demolition. In 2019, an agreement was signed between the NNPP and the Department of

Energy Office of Environmental Management (DOE-EM) to perform decontamination and

NRF Environmental Summary Report

decommissioning (D&D) at the Naval Nuclear Laboratory sites. At NRF, the three nuclear prototypes

were identified for D&D. The D&D work will be performed by the DOE-EM, Idaho Cleanup Project

contractor, for the next several years. This agreement transfers operational, radiological, and

environmental responsibilities for the D&D work associated with the three prototypes to DOE-EM.

The S1W prototype, surrounding area, and support areas were formally turned over to the DOE-EM

contractor in January 2022. DOE-EM became responsible for compliance with all regulatory

requirements, any permitting, monitoring, and reporting activities associated with this project.

Therefore, this report does not provide any environmental information related to these activities.

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NRF Environmental Summary Report

5.0 WASTE GENERATION AND CONTROLS

The NRF has never been a manufacturing facility; consequently, the total quantities of chemical and

radioactive materials handled on the NRF Site have typically been small. When sufficient quantities

are accumulated, asphalt, batteries, cardboard, clothing/laundry, computers/cell phones, cooking oil,

concrete, lead, light bulbs, mercury containing devices, petroleum oil, scrap metals, soil/gravel, and

toner cartridges, are shipped off-site for recycling. NRF continues to minimize the generation of

hazardous and mixed wastes to the maximum extent practicable.

NRF remediation activities, the ECF, and other support facilities have generated quantities of low-

level radioactive solid waste during their operations. A discussion of current and past waste

management operations follows.

5.1 Current Waste Management Programs

5.1.1 Radioactive Waste Management

Liquid and solid radioactive wastes are generated and controlled by Site operations. In addition,

NRF manages radioactive and chemically hazardous (mixed) wastes in accordance with regulations

in the Resource Conservation and Recovery Act (RCRA) administered by the State of Idaho. NRF

has maintained a rigorous radioactive waste control and minimization program for many years. The

generation processes and the minimization program are described below.

Radioactive Liquid Waste. Federal regulations applicable to commercial nuclear industries permit

the discharge of low-level radioactive liquids if they meet concentration standards established by the

Nuclear Regulatory Commission. The DOE regulations also permit similar discharges of low-level

radioactive liquids. NRF has operated to a far more rigid disposal standard for many years. At the

NRF, water used for radiological purposes is collected, processed to remove the radioactivity, and

reused. No low-level radioactive liquids are discharged from NRF operations. The reuse processing

systems, include collection tanks and particulate filters, as well as activated carbon columns and/or

mixed bed ion exchange resin columns to remove inorganics. The water is reused in operations

involving radioactivity to the maximum extent practicable. The water reuse practices assure that

over 99.9 percent of the gamma radioactivity contained in liquids associated with Site operations is

removed and sent off-site for disposal. The remaining 0.1 percent is retained in the water that is

reused.

Radioactive Solid Waste. Solid radioactive wastes are generated at the NRF as a result of

operations, remediation, and maintenance activities. Included in this waste are process system

filters, expended activated charcoal and resin, contaminated components, pieces of insulation, rags,

sheet plastic, paper, filter paper, protective clothing, and towels resulting from radiochemistry and

radiation monitoring operations, and ventilation filters.

When practicable, solid radioactive waste is dismantled to reduce the volume that must be shipped

for direct disposal. Solid radioactive wastes are packaged and shipped in accordance with

requirements of the Department of Transportation. Remote handled wastes are disposed of at the

INL Remote-Handled Low-Level Waste Disposal Facility. Contact handled waste is disposed of

through commercial waste processing vendors. In addition, some solid radioactive waste associated

with CERCLA removal actions is disposed at the Idaho CERCLA Disposal Facility located on the

INL.

Radioactive Airborne Effluents. Exhaust systems that service radiological facilities with a potential

to generate airborne radionuclides are designed and operated to ensure the control of airborne

NRF Environmental Summary Report

radioactivity. These systems utilize high efficiency filters for the removal of particulate radioactivity

from the exhaust air. Additionally, exhaust from fuel examination is passed through a second bank

of high efficiency particulate air (HEPA) filters as well as charcoal absorbers. Expended filters and

charcoal absorbers are disposed of as solid radioactive waste.

All exhaust system, HEPA filters are tested in place following installation, and routinely thereafter.

The procedure, called “DOP Testing”, is performed using 0.7-micron diameter dioctylphthalate

(DOP) aerosol particles. The installed filter must exhibit an overall collection efficiency of 99.95

percent or higher to be acceptable for use.

In addition, exhaust systems from radiological facilities are sampled for radioactivity. Monitoring

results are reported annually in the NRF Environmental Monitoring Report.

Radioactive Waste Minimization. NRF has also maintained a radioactive waste minimization

program. The program includes work to identify and eliminate the generation of radioactive materials

and its subsequent wastes. The volume of radioactive wastes generated varies each year based on

current work evolutions. NRF recycles, incinerates, and super-compacts radioactive materials

through its waste processing vendors when feasible.

5.1.2 Non-Radioactive Waste Management

Site operations produce a variety of industrial waste products including sewage effluent, chemical

wastes, boiler exhaust gases, and other products typical of a large laboratory facility. All such waste

products are controlled in accordance with applicable federal and state laws. In addition, NRF has

a hazardous waste minimization program. Each area is discussed below.

Non-Radioactive Liquid Waste. In February 2012, NRF began operation of a 21-acre, dual cell,

lined sanitary sewer lagoon complex. This sanitary sewer lagoon complex is located northeast of

the previous lagoons. These lagoons were installed to replace the existing clay-lined lagoons that

had been in operation since the 1960s. This lagoon system was constructed to meet the state design

standards for wastewater lagoons. A valve box located in the southern berm of the lagoon allows

wastewater to be directed to either one or both of the cells depending upon the volume of wastewater

being generated. A valve within an equalization line that is located at the opposite end of the lagoons

is used to stabilize the water level between the cells if needed. Treatment includes aerobic and

anaerobic microbial digestion of sewage, along with evaporation of water.

Non-hazardous, non-sewage wastewater from storm water and snowmelt runoff is routed to the IWD.

The IWD is a large network of covered pipelines and uncovered channels of various sizes located

within and outside the Site. In 1980, NRF eliminated discharges of water containing hazardous

constituents to the IWD with the exception of acid and base solutions which self-neutralized within

the ditch. Discharge of acids and bases was then eliminated in 1985 when a neutralization facility

was installed, and the IWD now receives only non-hazardous, non-radioactive liquid wastes. The

IWD supports a variety of plant and animal life that is attracted to the reliable water flow, a feature

not otherwise available in this area of the eastern Idaho desert.

A small quantity of other waste liquids generated from other Site operations is controlled by several

methods depending on the volume and nature of the wastes. Methods used to assure safe disposal

include (1) collection and transfer of wastes that contain hazardous materials or unusable mixtures

of oils and liquids to a permitted off-site facility for reclamation, incineration, or treatment, (2)

NRF Environmental Summary Report

monitoring and control of chemical constituents to ensure that concentrations in effluent water

comply with applicable standards, and (3) employee training in waste management requirements.

Chemical wastes defined as hazardous in accordance with RCRA are managed in accordance with

applicable regulations.

In the case of storage tanks containing environmentally hazardous materials, precautionary

measures are taken to prevent or retain any leakage. The measures include periodic inspections,

use of revetments or berms, sealing of drains as appropriate, inclusion of liquid level gauges and

alarms in selected tanks, and removal of underground tanks.

NRF has removed all known electrical transformers containing liquid polychlorinated biphenyls

(PCBs) and disposed of them through appropriately licensed contractors. As a best management

practice, light ballasts containing PCBs are currently being eliminated or replaced. In addition,

samples are routinely collected on various materials prior to disposal to ensure no previously

unidentified PCBs exist.

Non-Radioactive Solid Waste. Non-hazardous demolition debris and other similar material are

disposed of in the INL landfill. The INL landfill is located approximately 10 miles south of NRF and

is operated in accordance with State of Idaho regulations.

NRF recycles as much material as practical. Most solid metal waste is accumulated and sold to a

scrap salvage vendor. In addition, aluminum beverage containers and cardboard material are

collected for recycling. No chemically hazardous wastes are sent to the landfill by NRF. Chemically

hazardous solids are controlled and disposed in accordance with the requirements of RCRA.

Non-Radioactive Airborne Effluents. Combustion gases from Site boilers are discharged through

elevated exhaust stacks. The boilers provide steam for heating and, therefore, are in maximum use

during the colder months. Regular opacity observations of emissions from the boilers confirms

compliance with applicable regulations. The grade of fuel oil used in the boilers is controlled and

monitored to ensure compliance with applicable regulations.

Other emissions from the Site are associated with backup diesel generators. The diesel generators

are operated infrequently for tests and comply with applicable regulations.

Non-Radioactive Waste Minimization and Pollution Prevention. NRF has a waste minimization

program that requires specific actions to identify and minimize waste producing operations, compare

minimization efforts year to year to demonstrate progress, and assess performance relative to waste

minimization goals. This is accomplished by establishment of strict procurement procedures,

substitution of non-hazardous materials where practicable, and other similar measures. A principal

component of the overall control program is the review of purchase orders prior to the acquisition of

chemicals at NRF. Purchase orders are reviewed to determine if the procurement of a hazardous

material is necessary, to assure excessive quantities are not ordered, and to determine if a suitable

nonhazardous substitute is available.

Typical waste minimization and pollution prevention actions taken in recent years include:

• Recycling of lead acid batteries.

• Careful control of the use of chemicals to minimize hazardous constituents and to minimize the

amount of excess chemicals that must be disposed of after completion of jobs.

• Training of employees to understand the hazards and to follow the proper controls for the

potentially hazardous materials used in their jobs.

NRF Environmental Summary Report

• Replacement of fluorescent light tubes with non-hazardous substitutes.

• Changing out PCB containing light ballasts with a non-PCB alternative.

• The recycling of thousands of pounds of: asphalt, batteries, cardboard, clothing/laundry,

computers/cell phones, cooking oil, concrete, lead, light bulbs, mercury containing devices,

petroleum oil, scrap metal, soil/gravel, toner cartridges, and wood.

NRF stresses environmentally sound management of wastes selected for disposal or recycling. NRF

requires that contractors' practices conform to all applicable regulations and, when practicable, use

advanced disposal technology for NRF wastes.

NRF will continue to evaluate processes, such as chemical purchases and operations, to identify

ways to further reduce the generation of hazardous wastes.

5.1.3 Remediation Programs

5.1.3.1 Remediation Under CERCLA

CERCLA, as amended by the Superfund Amendments and Reauthorization Act (SARA) of 1986,

requires all facilities to evaluate the presence of hazardous substances in former disposal areas and

rank themselves according to a national system that identifies facilities requiring prompt remedial

action. Federal and state agencies are responsible to review the self-evaluation and officially

establish the Site ranking. Facilities with high rankings are considered for placement on a NPL for

cleanup in accordance with direction from the EPA. Otherwise, sites are addressed according to

requirements of the state where the site is located. NRF completed the self-evaluation and submitted

the results to the EPA and State of Idaho in April 1988.

While the evaluation concluded that the NRF Site itself did not warrant inclusion in the NPL, the

combined ranking with other INL facilities resulted in placement of the entire INL Site on the NPL.

Accordingly, the State of Idaho, EPA, and the DOE have entered into an FFA/CO to remediate

inactive waste disposal sites. NRF conducted its remedial work under this FFA/CO. The FFA/CO

includes an action plan, which establishes the remediation priorities for the INL and certain

enforceable deadlines.

Prior to listing the INL on the NPL, NRF was conducting remedial actions at Solid Waste

Management Units and Land Disposal Units under provisions of the INL RCRA Consent Order and

Compliance Agreement (COCA). The COCA, issued by the EPA under authority of Section 3008(h)

of RCRA, coordinated activities aimed at investigating and, where necessary, remediating sites to

minimize potential harm to human health and the environment from past hazardous waste disposal

practices at the INL. The COCA was superseded by the FFA/CO.

5.1.3.2 Facility Deactivation

In 1984, NRF established a program to deactivate and minimize the number of facilities and areas

requiring radiological controls. The program has accomplished the removal and decontamination of

many radiological facilities consisting of tanks, pipelines, soil, and structures.

In 2022, DOE-EM began planning for removal of S1W and A1W prototypes and associated buildings

at NRF. Demolition of the S1W prototype is expected to start in 2023.

NRF Environmental Summary Report

5.2 Past Waste Management Practices

Radioactive waste management practices have evolved over the years consistent with advances in

technology and changes in regulatory requirements. NRF has always maintained an environmental

program in accordance with the national standards in effect at the time. In 1979, NRF took action to

eliminate discharges of liquids containing even trace amounts of radioactivity. This action was not

required by rule or law. It was done because it had become feasible and was consistent with the

conservative engineering approach followed by the NNPP of minimizing releases of radioactivity.

Non-radioactive waste management practices evolved in a similar manner. Land burial of chemicals

on-site was conducted in the 1950s and 1960s, consistent with accepted practice across the country

at the time. On-site burial of even small amounts of such materials at NRF was stopped in 1966.

Current NRF waste practices incorporate all controls required by applicable federal and state

regulations. Each of these areas is discussed below.

5.2.1 Past Radioactive Waste Management

NRF has always been involved in handling radioactive materials and in maintaining a radioactive

waste management program. For example, requirements for treatment and disposal of solid and

liquid wastes were provided for in the design of the operating facilities. Features such as retention

tanks and evaporators for liquid waste, surface and subsurface facilities for temporary storage of

waste, and air cleaning systems using high efficiency filters were incorporated into the initial design

of the facilities.

Radioactive Liquid Waste. Liquid wastes were managed by a variety of methods. NRF has

complied with the then-existing limits for discharges of water containing low concentrations of

radioactivity since the beginning of Site operations in the 1950s. Water containing low levels of

radioactivity was discharged to specific, defined areas on NRF property that were monitored and

controlled. Water exceeding radioactivity concentration limits was not discharged directly to the

environment, but instead was processed through ion exchangers to remove as much radioactivity as

practicable, or diluted to permissible levels prior to discharge. The discharge of water containing

even trace amounts of radioactivity was discontinued in 1979.

Today, concentrations of radioactivity in the surface soils near the leaching beds are near

background levels. Approximately 33 curies are estimated to remain in the beds, out of the 345

curies released since Site operations began. There is no evidence that the radioactivity, except

tritium (See section 5.2.4, Groundwater Monitoring), has left the immediate area of the beds as

confirmed by sampling performed as part of the NRF Comprehensive RI/FS. The decrease in curie

content is due to steady decay of cobalt-60 and cesium-137, the major radionuclides of concern in

the leaching beds, with half-lives of 5.3 and 30 years, respectively. These areas were identified for

remedial actions as part of the NRF Comprehensive RI/FS and agreed to by the State of Idaho and

EPA in the ROD signed in September 1998. The remedial actions for these areas consisted of

placement of an engineered cover, institutional controls, and monitoring. The placements of the three

engineered covers over these areas were completed in 2004 and are now under institutional controls

with periodic monitoring.

Radioactive Solid Waste. Most of the radioactive waste volume generated by the NRF has been

low-level waste. Solid waste generated at NRF and sent to the INL waste disposal facilities were

characterized as follows:

Incinerable Low-Level Radioactive Waste (Radiation levels less than 20 millirem per hour (mrem/hr)

at the surface of each container):

NRF Environmental Summary Report

• This type of waste consisted of paper and cloth wipes, protective clothing, wood and floor

sweepings. These waste were collected in waste cans, packaged in boxes and sent to the

Waste Experimental Reduction Facility (WERF) for incineration. The ash and residue were

shipped to the RWMC for disposal. Incineration of radioactive waste ceased in the fall of 2000.

Compactable Low-Level Radioactive Waste (Radiation levels less than 200 mrem/hr at the surface

of each container):

• This included such wastes as contaminated equipment, air filters, and materials that exceeded

the radiation limits for incineration. These wastes were packaged in polyurethane bags and

transported by cargo container to the WERF for compaction. The processed wastes were then

shipped to the RWMC for disposal. In August 2001, compaction at the WERF ceased.

Size-reducible Low-Level Radioactive Waste (Radiation levels less than 100 mrem/hr at contact with

the item):

• This included such wastes as contaminated equipment that could be segmented to reduce the

volume by at least a factor of three. Until August 2001, these wastes were packaged and

transported to the WERF for segmentation. The processed wastes were shipped to the RWMC

for disposal.

Contact-Handled Non-processible Low-Level Radioactive Waste (Radiation levels less than 500

mrem/hr at 1 meter from the surface of the container):

• This included such waste as contaminated equipment that was not acceptable as incinerable,

compactable, or size-reducible waste. These wastes were packaged in boxes or drums and

sent to the RWMC for disposal. In October 2008, disposal of contact-handled wastes at the

RWMC ceased.

Remote-Handled Low-Level Radioactive Waste (Radiation levels greater than 500 mrem/hr at the

surface of each container):

• This included such waste as irradiated metallic scrap. This waste was generated in the ECF

water pools and shielded cells. The irradiated metallic scrap was packaged in containers

underwater using remote handling equipment. Waste generated in the shielded cells were

placed in containers while in the cells, removed to the water pools, and placed in shipping

containers underwater. Specially designed shielded shipping casks were used to transport this

waste by truck for burial at the RWMC. The radiation levels on all shipments in areas

accessible to the general public were less than the limits imposed by the Department of

Transportation for radioactive material shipments over public highways.

• NRF has also examined and tested fuel from nuclear-powered warships, the Shippingport

Atomic Power Station, and specimens that were irradiated in test reactors. These examinations

resulted in waste containing small amounts of irradiated fuel. The individual waste items

containing irradiated fuel from NRF did not consist of entire cores or whole fuel cells, which

were considered a valuable resource at the time and retained for reprocessing. Prior to 1971,

about 220 kilograms of mostly irradiated natural uranium was disposed of at the RWMC, in

accordance with the radioactive waste requirements at that time. In 1971, the Atomic Energy

Commission modified the requirements for low-level waste that precluded the burial at the

RWMC of wastes containing irradiated fuel. Accordingly, since 1971, NRF has not disposed

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of waste at the RWMC that contains irradiated fuel. In April 2021, the RWMC closed and

disposal of Remote-Handled Low-Level Waste moved to another INL facility in February 2023.

Radioactive Airborne Effluents. Ventilation air from radiological facilities is discharged to the

atmosphere through exhaust vents and stacks. Prior to release, air with significant potential to carry

radiological particulates is passed through HEPA filters and monitored to ensure compliance with

existing radiation protection guidelines. Additionally, exhaust from fuel examination is passed

through a second bank of HEPA filters as well as charcoal absorbers. The filtered air exhausted

from NRF radiological facilities typically contains less particulate radioactivity than that in the air that

was drawn into the facilities.

Monitoring of exhaust air has been accomplished through the collection and analysis of samples of

the effluent. Sampling techniques used include filter papers (for particulates), activated charcoal

cartridges (for iodine gas), and molecular sieve canisters (for tritium).

Overall, less than an estimated 1,100 curies of radioactivity have been released to the atmosphere

during the period of 1953 through 1989, with the majority occurring in the 1950s. Most of the

radioactivity (over 80 percent) consisted of the inert gaseous isotopes argon, krypton, and xenon.

These inert gases do not deposit on surfaces and are readily dispersed in the atmosphere. The

remainder consisted of smaller amounts of other beta-gamma emitting activated corrosion and wear

products, carbon-14, and tritium and trace quantities of fission products. Since 1990, airborne

emissions of radionuclides have typically been less than 2 curies per year, and annual exposure to

the public from these emissions has been less than 0.001 mrem per year. For perspective, federal

regulations allow up to 10 mrem per year exposure to the general public from airborne emissions

from DOE facilities.

In addition to the regular annual releases, a single release occurred in 1955 during the performance

of an engineering test to obtain information on the effects of boiling conditions in naval reactors.

During the testing, a specially designed and instrumented test assembly was subjected to carefully

controlled conditions designed to explore fuel element integrity beyond operational limits in effect at

the time. Small amounts of fission products were released from the test assembly, most of which

were retained in the primary coolant. A conservative estimate of the amount of radioactivity released

from the Site was 870 curies. The radioactivity remaining in this coolant went to the leaching beds

or purification media. The purification media was subsequently disposed of at the RWMC.

Conservative calculations indicate the maximum exposure to a member of the general public was

0.5 mrem, which is only five percent of today's general public annual exposure limits from DOE

facilities.

5.2.2 Residual Radioactivity

There are several localized areas of soil on NRF property that contain small amounts of residual

radioactivity from historical liquid radioactivity releases. These areas were included in remedial

actions as determined by the Comprehensive RI/FS and agreed to by the State of Idaho and the

EPA in the ROD signed in September 1998. The specific affected areas that have undergone

remedial action are discussed below:

S1W Tile Drain Field and L-shaped Sump. This area consisted of a below-surface sump and

various underground, tile drain field pipes downstream of the sump. The drain field was likely used

between 1953 and 1955 for sewage and radioactive liquid discharges. The sump was isolated from

the drain field in 1955 and was used until 1960 as part of the sewage system. Sampling indicated

NRF Environmental Summary Report

that any significant contamination at the drain field was likely confined to within the pipes. Remedial

actions were completed in 2002.

Underground Piping to Leaching Pit. In 1955, a drain field was constructed south of S1W, adjacent

to the S1W Tile Drain field. The drain field was an underground, perforated pipe. This drain field

was used for radiological discharges after the S1W Tile Drain field was no longer used. The drain

field was used for discharges until 1960. Sampling indicated most of the contamination at this drain

field was within three to five feet of the underground pipe. Contaminated soil was removed from this

area. Remedial actions were completed in this area in 2003.

S1W Leaching Pit. In 1957, a pit was dug at the end of the underground, perforated pipe drain field.

This pit was known as the S1W Leaching Pit. The pit was used from 1957 until 1961 when it was

filled in with soil. An asphalt cover was placed over the leaching pit location in 1978 and was

removed in 2003 as part of the remedial actions. An engineered cover was constructed over this

area and completed in 2004.

S1W Leaching Beds. The first S1W Leaching Bed was constructed in 1960. The bed was an open

pond that allowed the water to evaporate or infiltrate into the ground. A second bed was constructed

in 1963 adjacent to the first bed. The beds originally received effluent from the S1W Prototype plant

and later received effluent from the S5G and A1W Prototypes and the ECF. The beds were used

from 1960 to 1979. Sampling indicated the extent of contamination in this area was primarily within

the soil directly below the leaching beds. As part of remedial actions, contaminated soil from other

CERCLA remedial action sites was consolidated into these beds. An engineered cover was

constructed over this area and completed in 2004.

S1W Retention Basins. The S1W Retention Basins were constructed in 1951. The basins were

two concrete structures, which received radioactive effluent from the S1W Prototype plant and later

received effluent from the S5G and A1W Prototype plants and the ECF. The basins were used as a

radioactive liquid storage facility prior to discharging the liquid to the discharge areas. One of the

basins is known to have leaked in 1971. The leak was directly below the basins. Remedial actions

were completed at this area in 2001. These actions included the removal of the basins and

associated contaminated soil.

A1W Leaching Bed. The A1W Leaching Bed was constructed west of NRF in 1957. The bed was

not an open pond like the S1W Leaching Beds. The A1W Leaching Bed was similar to a drain field

with underground, perforated pipes distributing the liquid to an area constructed of gravel and sand.

The bed was used continually from 1958 to 1964 for effluent discharges from the A1W Prototype

and the ECF. The bed was used sporadically from 1964 until 1972, when use of the bed was

discontinued. Sampling indicated that the extent of contamination at the A1W Leaching Bed was

limited to the soil within and directly below the leaching bed. An engineered cover was constructed

over the area and completed in 2004.

Old Sewage Basin. In 1956, a sewage basin was constructed to the southeast of NRF. The sewage

basin was an open pond. The basin was cross-contaminated with the radiological discharge system

in 1956. The basin was enlarged in 1957 and was used until 1960. The basin was then filled in with

soil. Remedial actions began at this site in 2000. An Explanation of Significant Difference to the

ROD was issued for this site in 2002 that modified remedial actions to include the construction of an

engineered cover over the area. The cover was constructed over this area and completed in 2004.

NRF Environmental Summary Report

Sludge Drying Bed. The sludge drying bed was constructed in 1951 as part of the sewage system

at NRF. The bed was a concrete slab approximately five feet below the surrounding ground

elevation. The bed received sludge from the sewage system. The bed was suspected to have been

contaminated with radionuclides when the sewage system was cross-contaminated with the

radiological discharge system in 1956. Remedial actions were completed at this area in 2002 with

the removal of the bed and associated soil.

A1W/S1W Radioactive Line Near Butler Building 19. During the construction of the A1W

Prototype, a pipe was installed from the A1W Prototype to the S1W Retention Basins that allowed

radioactive effluents from A1W to be sent to the S1W radioactive discharge system. The pipe was

buried approximately six feet below the surface. The pipe is known to have leaked on one occasion.

During decontamination and decommissioning work at NRF in 1995, portions of the pipe were

removed and contamination was detected in the soil. Remedial actions were completed at this site

in 1999. Residual contamination was left in place in the soil. During the demolition of the adjacent

S1W Spray Pond #1 the residual contamination was remediated with agency concurrence. This

removal action was completed in early 2010.

Seepage Basin Pump-out Area. This site is an area that physically surrounds the sewage disposal

basin and was formed when the radioactively contaminated contents of the basin were pumped out

in 1958. Additional contaminated areas associated with the Seepage Basin Pump-out Area

(CERCLA Site NRF-43) were found in 2009 and 2010. These areas were remediated in 2012 by the

removal and disposal of soil with contamination above the CERCLA remediation goal. A minor

change to the ROD was issued with concurrence by the State of Idaho and EPA that documented

the remedial action.

5.2.3 Past Non-Radioactive Waste Management

Historically, NRF has used the IWD for disposal of large volumes of cooling water, and smaller

volumes of water containing low concentrations of heavy metals, acids and bases, storm water, and

snow-melt runoff. The acids and bases were self-neutralizing and hence rendered each other non-

hazardous. The ditch functioned in compliance with applicable standards throughout its use. Other

chemical wastes were disposed of by landfill, consistent with national waste management practices

of the time.

Since 1980, all chemical wastes have been packaged in approved containers and disposed of

through approved off-site disposal facilities. Acidic and caustic solutions from the regeneration of

resin used in a deionized water facility were discharged to the IWD, where they self-neutralized until

1985 when neutralization tanks were installed and these discharges were discontinued. In 1997, a

reverse osmosis system replaced the ion exchange resin for the deionized water facility thus

eliminating the need for acidic and caustic solutions completely.

Under the provisions of the INL FFA/CO, inspections, site characterizations, and geological

investigations have been performed on identified solid waste disposal sites. These areas include

pre-existing small depressions, as well as pits created by excavation to obtain building materials.

Consistent with common practices, the disposal areas were historically used for burning and disposal

of ordinary refuse (cardboard, paper, and other combustible materials). Evaluations indicate that,

with the exception of the low concentrations of liquids discharged to the IWD, most chemical wastes

were not land disposed. Confirming evidence of this has been provided by a review of facility

drawings and photographs dating from the 1950s. Characterization of these areas has shown no

significant effect on the environment, consistent with expectations. A remedial action that included

NRF Environmental Summary Report

the placement of covers on three landfill areas was completed. The covers provide additional

assurance of no potential future impact of these areas on the environment.

Cooling Towers and Spray Ponds. The S1W Prototype used two large spray ponds (capacity

2,250,000 gallons each) to cool its secondary water. These ponds leaked in the 1950s and 1960s,

introducing small amounts of chromium corrosion inhibitor into the soil directly beneath the structure.

Upon detection of small amounts of chromium in a nearby well being used to supply Site water

needs, the water supply was shifted to another well and the ponds were ultimately repaired.

Chromium was not used as a corrosion inhibitor in the spray ponds after 1966 and was not detected

at elevated levels in this well after the repairs.

In 1997, a decision was made to demolish the S1W Spray Pond #2. Additional data was collected

at Spray Pond #2 in preparation for demolishing the spray pond. Sample results showed slightly

elevated amounts of chromium. The qualitative risk associated with Spray Pond #2 was determined

to be low according to CERCLA guidelines. The spray pond has since been demolished and is a

CERCLA No Action site.

In 2008, a decision was made to demolish the S1W Spray Pond #1. Samples were collected from

this area in preparation for removing this structure. As with the S1W Spray Pond #2, sample results

for the S1W Spray Pond #1 showed slightly elevated amounts of chromium. The qualitative risk

associated with the S1W Spray Pond #1 also was determined to be low according to CERCLA

guidelines. The S1W Spray Pond #1 was then added to the INL Action Memorandum for General

Decommissioning Activities under the Idaho Cleanup Project. As such, it was demolished under a

CERCLA non-time critical removal action. The spray pond was removed in 2009.

The cooling towers for the A1W and S5G Prototypes used a process of continuous blowdown of the

supply water to control natural concentrations of solids, subsequently discharging purged water into

the IWD. In the 1950s and 1960s, blowdown water from the A1W cooling tower contained chromium

compounds used as corrosion inhibitors, however, the use of chromium compounds ceased after

1966. This particular chromium was nearly exclusively in the trivalent state instead of the hexavalent

form. Investigations of sediment in the IWD indicate that detectable chromium present in the

sediments is not migrating, and the levels are too low to have a measurable impact on the

environment.

The A1W Cooling Tower was demolished in 1995 with its basin buried in its original location. The

S5G Cooling Tower was dismantled in 1997 except for the concrete basin, which is currently used

for the storage of emergency firefighting water.

5.2.4 Groundwater Monitoring

NRF manages a comprehensive groundwater monitoring program under CERCLA to determine

what, if any, effects the operations at NRF have had on the quality of the groundwater. This

monitoring program, which is conducted in cooperation with the USGS, indicates that NRF

operations have not significantly degraded the quality of the groundwater. NRF data, in conjunction

with other INL groundwater data, is also used in an independent program managed by the USGS

that monitors groundwater on the INL Site. The State of Idaho INL Oversight Program co-samples

NRF and other INL groundwater monitoring wells on a periodic basis to verify programmatic

monitoring results.

NRF Environmental Summary Report

In addition, the USGS and the State of Idaho INL Oversight Program performs independent

groundwater sampling of the INL Site to ensure that INL operations, including NRF, do not adversely

impact the general public or the water quality of the SRPA. Results of these monitoring programs

indicate that no hazardous constituents or significant radioactivity associated with INL operations are

migrating beyond the INL Site boundary (Reference 3, 5, and 6). This monitoring provides an

additional confirmation that there is no significant adverse impact on the aquifer from NRF

operations.

Based on information collected during a 1994 fitness evaluation of the wells used for groundwater

monitoring in conjunction with a CERCLA ROD that defined monitoring requirements at NRF, the

NRF CERCLA groundwater monitoring network was established in 1995 by constructing six new

wells and eliminating seven existing wells that had been used in the pre-1995 (non-CERCLA) NRF

groundwater monitoring network. In 2007, well NRF-13 was removed from the CERCLA

groundwater monitoring network because of poor sample quality. In 2009, a new well (NRF-16) was

constructed to replace NRF-13. Based on concurrence by the IDEQ and EPA, well NRF-16 was

added to the CERCLA monitoring network in late 2010 and wells USGS 12 and NRF-7 were

removed. Of the 11 wells comprising the CERCLA monitoring network, 8 wells have been designed

specifically to monitor the upper portion of the SRPA near NRF. Although the remaining three wells

(built prior to 1990) included in the current CERCLA groundwater monitoring network draw water

from a larger portion of the aquifer (greater than 50 feet), they are used to supplement data collected

from the newer wells (built after 1995) in the current monitoring network.

Six additional wells are located within the NRF security fence. Two are classified as drinking water

wells (NRF-3 and NRF-14) and are monitored to meet the requirements of the Safe Drinking Water

Act (SDWA). Two are production wells (NRF-1 and NRF-4) used for the fire main system and lawn

watering at NRF. The remaining two wells are not currently being used for any water production

(NRF-2 and NRF-5). These six wells are not part of the CERCLA groundwater monitoring program;

however, samples from NRF-3 and NRF-14 are analyzed for metals and ions and confirm that

operations at NRF have had no adverse effect on the groundwater.

The 11 CERCLA groundwater wells were sampled on a routine basis for both chemical and

radiological parameters until May 2018. As of May 2018, NRF no longer samples monitoring wells

USGS 97, USGS 98, and USGS 99 as part of the CERCLA monitoring program. Data from these

wells consistently showed that the groundwater concentrations for constituents of concern relative

to the CERCLA monitoring program were at or near regional background levels. Future monitoring

of these wells will only be done on an as-needed basis to provide additional water quality information.

The remaining eight CERCLA groundwater wells will continue to be sampled on a routine basis.

Sample results indicate that radioactivity (except tritium) occurs in the groundwater at levels that are

at or near natural background levels. Tritium is found at levels that slightly exceed background levels

but are significantly below regulatory concerns.

Since the last report, no solvents or laboratory chemical concentrations were measured above

National Primary Drinking Water Standards.

Non-hazardous sodium, chloride, magnesium, potassium, and sulfate ions are detectable at

concentrations slightly above the natural background levels in the down-gradient monitoring wells.

The sodium and chloride ions (a saline mixture as in table salt) are present due to the previous use

of common water softening agents for domestic water treatment. This saline solution entered the

groundwater via the non-hazardous wastewater discharges to the IWD. Chloride concentrations

NRF Environmental Summary Report

exceeded secondary standards in NRF-6. The sulfate ion concentrations are below secondary

standards. There are no drinking water standards for sodium, magnesium, and potassium.

The secondary standard for aluminum and iron was exceeded occasionally in various wells over the

past few years. These samples were filtered to remove particulate matter and reanalyzed. Filtered

sample results were below the secondary standards indicating that the aluminum and iron were

attributed to sediment in the water rather than dissolved in the water. Secondary standards are

guidelines pertaining to groundwater constituents that may cause aesthetic effects in drinking water.

NRF-6 is nearest to the IWD and thus most affected by previous saline discharges to the ditch.

To summarize, no groundwater monitoring results exceeded National Primary Drinking Water

Standards, confirming that NRF operations have not had a significant impact on the environment.

Individual results of the chemical and radiological groundwater monitoring programs are found each

year in the annual NRF Environmental Monitoring Report.

NRF Environmental Summary Report

6.0 MONITORING PROGRAMS

NRF maintains a comprehensive multimedia environmental monitoring program covering all aspects

of NRF Site operations. This program has been developed to detect any environmental effects of

Site operations that might occur and to demonstrate compliance with applicable federal and state

environmental requirements. Data from the monitoring programs has demonstrated that operating

procedures used at NRF adequately protect the environment.

The environmental monitoring program includes the routine monitoring of industrial (see Section 4.2

Industrial Waste Ditch) and sanitary liquid effluents, sediment, gaseous and particulate airborne

emissions, soil and vegetation, drinking water, groundwater, soil gas, and environmental radiation

levels. In addition to the routine monitoring, NRF has conducted extensive special monitoring of the

areas of the NRF Site potentially affected by chemical and radiological residues. Evaluation of the

environmental data indicates that NRF operations continue to have no adverse effect on the

environment. A detailed description of environmental monitoring program results is provided each

year in the annual NRF Environmental Monitoring Report.

NRF Environmental Summary Report

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NRF Environmental Summary Report

7.0 ASSESSMENT OF ENVIRONMENTAL IMPACTS

With respect to radioactivity, NRF has from its beginning monitored potential sources of releases of

radioactivity to the environment from the NRF in liquid and airborne effluents. Releases of

radioactivity have been at levels typically far below limits prescribed by the appropriate federal, state,

and local authorities and have resulted in no measurable radiation exposure to any member of the

general public.

Releases of water containing low levels of radioactivity to various disposal basins, leaching beds,

and retention basins were made principally in the 1950s and 1960s. NRF discontinued this practice

in 1979 and estimates the residual radioactivity at approximately 33 curies.

NRF has employed quantitative models that conservatively estimate potential exposures. These

models consider exposure pathways that include using water that has passed through the INL for

drinking and irrigation, breathing the air, and eating regional animal and vegetable food. The most

recent assessment shows that the potential radiation exposure to a member of the public from NRF

operations was approximately 0.00034 mrem for the entire year. Further, the dose is negligible when

compared to the naturally occurring background radiation dose of approximately 366 mrem per year

for residents of southeast Idaho. The dose is also much less than the approximate 3 mrem that an

individual would receive from a single cross-country airplane flight.

Since operations began, NRF has also monitored non-radioactive Site effluent water and air

consistent with state and federal regulations to ensure they meet the requirements of applicable

environmental standards. Results of all effluent monitoring confirm that the operation of NRF has

had no significant impact on the environment. In addition, current monitoring results indicate no

contaminants, solvents, or laboratory chemicals exist above National Primary Drinking Water

Standards in the groundwater in the vicinity of NRF. This is confirmed by independent monitoring

conducted by the USGS and the State of Idaho INL Oversight Program. Thus, NRF operations have

had no significant effect on the environment, including the SRPA.

Hazard ranking calculations performed according to federal guidelines for judging the significance of

chemical and radioactive residues have been conducted in accordance with federal law. These

calculations indicate that the NRF scores below the cutoff for designation to the NPL (Superfund) of

high priority sites requiring prompt action to protect public health and safety. While NRF did not

qualify for listing on the NPL as an individual facility, it was included with other INL facilities in the

FFA/CO and Action Plan signed in 1991.

Under the FFA/CO, 87 sites were identified at NRF for investigation to determine potential risks to

human health and the environment. Thirteen of the 87 sites were evaluated prior to the FFA/CO

under the COCA. The remaining 74 sites were assessed as CERCLA-type investigations. The

CERCLA investigations included Track 1, Track 2, and RI/FS type investigations. A Track 1

investigation involved sites that were believed to have a low probability of risk and sufficient

information available to evaluate the sites and recommend a course of action. A Track 2

investigation involved sites that did not have sufficient data available to make a decision concerning

a level of risk; for these sites, collection of additional data was necessary. A RI/FS is the most

extensive investigation and attempts to characterize the nature and extent of contamination, to

assess risks to human health and the environment from potential exposure to contaminants, and to

evaluate cleanup actions. In addition to the investigations performed for each site through a Track

1, Track 2, or RI/FS process, a comprehensive RI/FS was performed to assess the potential

cumulative, or additive, effects to human health and the environment from all sites at NRF.

NRF Environmental Summary Report

The NRF Final ROD signed in 1998 divided the 87 sites into 3 groups: 63 sites were determined to

require no action, 12 require no further action and 12 sites required remedial action. Remedial

actions have been completed at the 12 sites under 2 RODs signed in 1994 and 1998 by the NNPP,

the State of Idaho, and the EPA. The original 87 sites are shown in Figure 3 and listed in Table 1.

The monitoring data collected and CERCLA Five-Year Reviews performed at NRF continue to

support the conclusion that NRF operations have not had a significant impact on the environment or

adverse effect on the surrounding communities. NRF has a well-defined program in place to protect

the environment, comply with state and federal environmental requirements and interagency

agreements, and address remediation of isolated residues from previous activities.

7.1 Remedial Action Areas

The Remedial Action areas included nine sites identified in the 1998 ROD and three landfill areas

identified in the 1994 ROD.

Remedial Actions for the three landfill areas as documented in the 1994 ROD included constructing

three covers over the landfills and conducting soil-gas and groundwater monitoring. Construction

actions were completed in 1996.

The NRF Comprehensive RI/FS involved extensive sampling and risk assessment to determine

appropriate remedial actions for nine sites with historical radiological releases. These remedial

actions were agreed to by the State of Idaho and the EPA in the ROD signed in September 1998.

Remedial actions for the nine sites identified in the 1998 ROD included excavating soil above

remediation goals and consolidating the soil at the S1W Leaching Beds, demolition of concrete

structures, and removal of underground piping with disposal at an INL facility, constructing three

engineered covers over four of the sites, and soil moisture and groundwater monitoring.

Construction and remedial activities were completed in 2004.

Institutional controls have been established at the remedial action sites. These controls include

limiting soil disturbance, periodic inspections and maintenance, and land use restrictions.

In 2006, 2012, 2017, and 2022, CERCLA Five-Year Reviews were completed for the remedial action

sites. The Five-Year Reviews concluded that the selected remedies for the Remedial Action areas

were effective and remained protective of human health and the environment. Furthermore, data

indicate that activities at NRF have not adversely affected groundwater quality.

Groundwater monitoring programs conducted by NRF, the USGS, and the State of Idaho INL

Oversight Program indicate that radioactivity associated with NRF operations is consistent with

natural background levels in the groundwater around the NRF Site.

Since the completion of the remedial actions identified in the RODs, additional CERCLA actions have

been performed as noted in Table 1. These additional CERCLA remedial actions were typically

addressed through minor changes to the 1998 NRF ROD with agency concurrence.

NRF Environmental Summary Report

Figure 3- NRF Waste Area Group 8

NRF Environmental Summary Report

Table 1- NRF Waste Area Group 8 Sites

REMEDIAL ACTION AREAS: (red) (Requiring Institutional Controls)

NRF-01, Field Area North of S1W (capped)

NRF-11, S1W Tile Drain field & L-shaped Sump

NRF-12A, Underground Piping to Leaching Pit

NRF-12B, S1W Leaching Pit

NRF-14, S1W Leaching Beds

NRF-17, S1W Retention Basins

NRF-19, A1W Leaching Bed

NRF-21A, Old Sewage Basin

NRF-21B, Sludge Drying Bed

NRF-51, West Refuse Pit #4 (capped)

NRF-53, East Refuse Pits & Trenching Area (capped)

NO ACTION SITES/RELE

ASED FOR UNRESTRICTE

D USE SITES

: (

green

)

NRF-02, Old Ditch Surge Pond

(1)

NRF-03, ECF Gravel Pit

NRF-04, Top Soil Pit (COCA)

NRF-05, West Landfill (COCA)

NRF-06, Southeast Landfill

NRF-07, East Landfill (COCA)

NRF-08, North Landfill

NRF-09, Parking Lot Runoff Leaching Trenches

NRF-10, Sand Blasting Slag Trench

NRF-13, S1W Temporary Leaching Pit

NRF-15, S1W Acid Spill Area

NRF-16, Radiography Building Collection Tanks

(1)(3)

NRF-18A, S1W Spray Pond #1

(1)

NRF-18B, S1W Spray Pond #2 & A1W Cooling Tower

NRF-20, A1W Acid Spill Area

NRF-24, Demineralizer & Neutralization Facility (COCA)

NRF-25, Chemical Waste Storage Pad (COCA)

NRF-26, Exterior Industrial Waste Ditch

NRF-27, Main Transformer Yard (COCA)

NRF-28, A1W Transformer Yard

(3)

NRF-29, S5G Oily Waste Spill

NRF-30, Gatehouse Transformer (COCA)

NRF-31, A1W Oily Waste Spill

NRF-32, S5G Basin Sludge Disposal Bed

NRF-33, South Landfill

NRF-34, Old Parking Lot Landfill (COCA)

NRF-35, Lagoon Landfill #1

NRF-36, Lagoon Landfill #2

NRF-37, Old Painting Booth

NRF-38, ECF French Drain

NRF-39, Old Radiography Area (COCA)

NRF-40, Lagoon Construction Rubble

NRF-41, East Rubble Area

NRF-44, S1W Industrial Wastewater Spill Area

NRF-45, Site Incinerator

NRF-46, Kerosene Spill (COCA)

NRF-47, Site Lead Shack (Building #614)

NRF-48, West Refuse Pit #1

NRF-49, West Refuse Pit #2

NRF-50, West Refuse Pit #3

NRF-52A, Old Lead Shack (Location #1)

NRF-52B, Old Lead Shack (Location #2)

NRF-54, Old Boilerhouse Blowdown Pit

NRF-55, Misc. NRF Sumps and French Drains

(4)

NRF-56, Degreasing Facility

NRF-57, S1W Gravel Pit (COCA)

NRF-58, S1W Old Fuel Oil Tank Spill

NRF-59, Original S1W Refuse Pit

NRF-60, Old Incinerator (COCA)

NRF-61, Old Radioactive Materials Storage & Laydown

Area

(1)

NRF-62, ECF Acid Spill Area

NRF-63, A1W Construction Debris Area

NRF-64, South Gravel Pit

NRF-65, Southeast Corner Oil Spill

NRF-66, Hot Storage Pit

(1)

NRF-67, Old Transformer Yard

NRF-68, Corrosion Area Behind BB11

NRF-69, Plant Service Underground Storage Tank Diesel

Spill

NRF-70, Boiler House Fuel Oil Release

NRF-71, Plant Service UST Gasoline Spill

NRF-72, NRF Waste Oil Tank

NRF-73, NRF Plant Services Varnish Tank

NRF-74, Abandoned Underground Storage Tanks

Between the NRF Security Fences

NRF-75, Fuel Oil Revetment Oil Releases

NRF-76, Vehicle Barrier Removal

NRF-77, A1W Fuel Oil Revetment Oil Releases

NRF-79, ECF Water Pool Release

NRF-80 A1W/S1W Radioactive Line Near BB19

(2)

NRF-81, A1W Processing Building Area Soil

(1)

OU 8-09, Interior Industrial Waste Ditch

(1)

No Further Action site released for unrestricted use.

(2)

Former Remedial Action site released for unrestricted

use.

(3)

Remedial action was taken by a minor change to the

ROD.

(4)

Site not shown in Figure 3.

NO FUR

THER ACTION SITES

: (

blue

)

(Requiring Institutional Controls)

NRF-22, A1W Painting Locker French Drain

NRF-23, Sewage Lagoons

(1)

NRF-42, Old Sewage Effluent Ponds

NRF-43, Seepage Basin Pumpout Area

(1)

NRF-82, Evaporator Bottoms Tank Release

NRF-83, ECF Hot Cells Release Area

(1)

Remedial action was taken by a minor change to the

ROD.

NRF Environmental Summary Report

7.2 No Action Sites

Based on Track 1 and Track 2 investigations and the RI/FS evaluation, a “No Action” decision was

made for those sites with no source of contamination present or a source present that represents an

acceptable risk for unrestricted use. This “No Action” decision means no future evaluations or follow-

ups are required. Seventy sites have been classified as “No Action” sites or released for unrestricted

use.

7.3 No Further Action Sites

Based on Track 1 and Track 2 investigations and the RI/FS evaluation, a “No Further Action” decision

was made for those sites with a source or potential source present, but for which an exposure route

is not available under current conditions. This “No Further Action” decision means that the site will

be included in a CERCLA review performed at least every five years to ensure that site conditions

used to evaluate the site have not changed and to verify the effectiveness of the “No Further Action”

decision. All monitoring data collected from the No Further Action sites are included in the CERCLA

Five-Year Reviews. Although no additional remedial action is required at this time, present

institutional controls, such as fencing and administrative controls on excavation, will be maintained.

If site conditions change, including present institutional controls, additional sampling, monitoring, or

action will be considered. Initially 12 sites were identified as “No Further Action” sites; however, this

number has been reduced to 6 when 6 sites were released for unrestricted use (equivalent to a No

Action site) through past CERCLA Five-Year Reviews and minor changes to the ROD. Six remaining

No Further Action sites continue to require institutional controls.

The most recent Five-Year Review for the No Further Action sites concluded that the selected

remedy for these sites is effective in limiting unauthorized access and excavation.

NRF Environmental Summary Report

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NRF Environmental Summary Report

8.0 AUDITS AND REVIEWS

The NRF Site uses a variety of training, controls, checks and cross-checks, audits, and inspections

to maintain high standards of environmental control. First, all personnel receive general awareness

training. Second, each worker is trained in appropriate controls as they relate to their specific job.

Third, written procedures must be followed verbatim. Fourth, dedicated technicians and supervisors

oversee all environmental monitoring and related work. Fifth, NRF maintains an audit program that

covers all environmental requirements and includes in-depth audits of specific areas. Sixth, the

NNPP maintains an on-site resident office with a technical staff, that audits and reviews NRF

environmental controls. The NNPP headquarters personnel also conduct periodic in-depth

inspections of these areas.

In addition, various aspects of the NRF environmental program are independently reviewed by other

government agencies. A complete listing of inspections performed since 1992 at NRF by the State

of Idaho or federal agencies is outlined in Table 2. No significant item of non-compliance in

operations has been cited as a result of these inspections.

NRF Environmental Summary Report

Table 2 – Environmental Inspections/Visits of the NRF Site

Topic Date Agency

RCRA 2011 (May) State of Idaho

CERCLA 2011 (July) State of Idaho

Wastewater Reuse

Facilities

2011 (July) State of Idaho

Air Emissions 2011 (September) State of Idaho

ECF Recapitalization 2011 (September) EPA (Region X)

CERCLA 2011 (September) State of Idaho/EPA (Region X)

Wastewater Reuse

Facilities

2012 (September) State of Idaho

Air Emissions 2012 (September) State of Idaho

RCRA 2013 (May) State of Idaho

Wastewater Reuse

Facilities

2013 (September) State of Idaho

RCRA 2014 (May) State of Idaho

CERCLA 2014 (May) State of Idaho

Wastewater Reuse

Facilities

2014 (September) State of Idaho

IDEQ Visit 2015 (September) State of Idaho

Air Emissions 2015 (October) State of Idaho

Wastewater Reuse

Facilities

2015 (October) State of Idaho

Sanitary Survey 2015 (November) State of Idaho

Air Emissions 2015 (December) State of Idaho

CERCLA 2016 (May) State of Idaho

Wastewater Reuse

Facilities

2016 (October) State of Idaho

Emergency Response

Presentation

2016 (November) State of Idaho

RCRA 2017 (June) State of Idaho

CERCLA 2017 (June) State of Idaho

Wastewater Reuse

Facilities

2018 (March) State of Idaho

Air Emissions 2018 (October) State of Idaho

Wastewater Reuse

Facilities

2019 (April) State of Idaho

RCRA 2019 (May) State of Idaho

RCRA 2019 (November) Department of Energy

CERCLA 2020 (February) State of Idaho/EPA (Region X)

NRF Environmental Summary Report

Topic Date Agency

Air Emissions 2021 (September) State of Idaho

Sanitary Survey 2022 (February) State of Idaho

CERCLA 2022 (June) State of Idaho/EPA (Region X)

NRF Environmental Summary Report

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NRF Environmental Summary Report

9.0 REGULATORY MATTERS

NRF has always responded promptly and effectively to conform to new environmental requirements

and will continue to do so. The following is a list of some of the major environmental laws that

regulate NRF operations:

Clean Air Act (CAA). The Clean Air Act Amendments of 1990 added the Operating Permits program

to the Clean Air Act on November 15, 1990. NRF participated in the INL Air Quality Tier I Operating

Permit (until January 12, 2018) but now participates in the INL Permit to Construct with Facility

Emissions Cap (from January 12, 2018, onward) relative to operation of various pieces of equipment

at the INL. NRF boilers and emergency diesel generators must comply with requirements in the

Permit to Construct with Facility Emissions Cap. NRF must also comply with all general provisions

of the permit, which includes recordkeeping, reporting, fugitive dust control, and visible emission

limits. The Permit to Construct with Facility Emissions Cap limits total INL emissions to 25 tons per

year of all Hazardous Air Pollutant (HAP) emissions and 10 tons per year of any single HAP, and

provides various limits on Criteria Air Pollutants. The EPA, under the Code of Federal Regulations

(CFR) 40 CFR 61 Subpart H, regulates radionuclide air emission sources at DOE Facilities. Annual

emission reports are provided to the EPA, as required by the regulations.

Clean Water Act (CWA). Storm water discharges to "Waters of the US" are required to be permitted

by this act. The INL is covered by the Idaho Pollutant Discharge Elimination System (IPDES) general

permits for discharges of storm water associated with industrial construction activities. These

permits specify storm water monitoring requirements and require Storm Water Pollution Prevention

Plans, which identify best management practices used to minimize pollution of storm water runoff.

Storm water from NRF does not discharge to "Waters of the US". NRF does not have a hydrologic

connection to “Waters of the US” and therefore there is no potential for storm water discharges to

reach regulated waters.

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). This

act, commonly known as Superfund, establishes requirements for the identification and location of

areas where hazardous materials have been released to the environment. NRF has prepared and

submitted documentation to the EPA and the State of Idaho concerning such areas, as required by

CERCLA. The submittal includes hazard-ranking scores calculated in accordance with EPA

methods used to judge the significance of waste sites. The ranking calculation concludes that the

NRF Site scores below the value that is used to determine whether a site warrants inclusion on the

NPL. An FFA/CO (also known as an Interagency Agreement) between the DOE, EPA, and the State

of Idaho has been executed since the combined score of all INL facilities qualified the INL for

inclusion on the NPL. The FFA/CO directs all remedial action activities to be conducted in

accordance with CERCLA. NRF participates in the activities outlined under the FFA/CO.

Emergency Planning and Community Right-To-Know Act (EPCRA). All federal agencies must

comply with the planning and reporting provisions of EPCRA. This subtitle requires facilities that

have extremely hazardous substances above their respective Threshold Planning Quantity to give

notice that these substances are present at that facility and to report releases of those substances

and other listed hazardous substances in excess of their respective reportable quantity. Reporting

is required for hazardous chemicals stored on-site in quantities greater than 10,000 pounds and for

Extremely Hazardous Substances present in quantities greater than 500 pounds or the Threshold

Planning Quantity (whichever is less) and toxic chemical emissions above threshold reporting limits.

NRF Environmental Summary Report

Federal Facility Compliance Act (FFCA). This act requires DOE facilities to prepare plans for

developing treatment capacity and technologies for sites that generate or store mixed wastes; mixed

wastes contain chemically hazardous and radioactive constituents. These plans are needed

because adequate capacity for treating mixed waste to the standards required by RCRA does not

currently exist. The FFCA requires Site Treatment Plans to be submitted to the regulatory state or

the EPA for approval. As required by statute, the INL (including NRF) obtained Idaho State approval

for the INL Site Treatment Plan in October 1995.

Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). The Insecticide Act of 1910

established the first federal control over the use of pesticides. In 1947, Congress enacted the

Federal Insecticide, Fungicide, and Rodenticide Act, which has been amended several times. By

1972, this law was virtually rewritten. This statute gave the EPA the authority over the field use of

pesticides and requires the registration of all pesticides used in the United States. The EPA restricts

the application of pesticides through a state administered certification program. Only state certified

commercial applicators or personnel under their supervision are allowed to apply restricted-use

pesticides at NRF.

Land Disposal Restrictions (LDR). The main purpose of the LDR program is to discourage

activities that involve placing untreated wastes in or on the land when a better treatment or

immobilization alternative exists. LDRs do not allow storage of restricted hazardous wastes, except

for the purpose of accumulating such quantities as are necessary to facilitate proper recovery,

treatment, or disposal. The amendments require that, prior to land disposal, all wastes meet

treatment standards based on the “best demonstrated available technology.”

Migratory Bird Treaty Act. The Migratory Bird Treaty Act of 1918, as amended, is intended to

protect birds that have common migration patterns between the United States, Canada, Mexico,

Japan, and Russia. Under this act, taking, killing, or possessing migratory birds is unlawful except

as permitted by regulation.

NRF is subject to a special purpose federal fish and wildlife permit that allows the removal or

relocation of a limited number of migratory bird nests under certain circumstances. The permit was

issued to the DOE and is applicable to all facilities on the INL. The permit requires the DOE to submit

an annual report to the US Fish and Wildlife Service of all migratory birds, nests, and eggs that were

intentionally taken and/or salvaged. NRF provides the DOE with information about permit activity

that occurs at NRF for inclusion in the report.

National Environmental Policy Act (NEPA). Significant construction, renovation, and demolition

activities are reviewed for their impact on the environment under the NEPA requirements as provided

by the DOE. Other physical construction projects or capital equipment that have the potential for

creating new emissions to the environment also receive a NEPA evaluation. Categorical Exclusions

and all NEPA documentation for NNPP sites, including NRF, are posted online at www.NNPP-

NEPA.US. This website is linked to the DOE website located at www.nepa.energy.gov.

Resource Conservation and Recovery Act (RCRA). This Act establishes requirements for the

proper treatment, storage and disposal of hazardous wastes. Currently, the NRF Site operates in

accordance with the applicable RCRA regulations and is a generator under the INL RCRA

Permit. The INL RCRA Permit and RCRA regulations include descriptive information, identification

of hazardous wastes, and waste management methods employed at NRF.

NRF Environmental Summary Report

Superfund Amendments and Reauthorization Act (SARA). This act revises and extends

CERCLA. CERCLA is extended by the addition of new authorities known as EPCRA of 1986. This

act is also known as Title III of SARA and provides for emergency planning and preparedness,

community right-to-know reporting, and toxic chemical release reporting. In compliance with these

requirements, NRF provides appropriate information to local emergency planning groups and

regulatory agencies in a comprehensive report submitted for the INL.

Toxic Substances Control Act (TSCA). The U.S. Congress enacted the Toxic Substances Control

Act in 1976. TSCA authorizes the EPA to secure information on all new and existing chemical

substances and to control any of these substances determined to cause an unreasonable risk to

public health or the environment. Unlike many other environmental laws, which generally govern

discharge of substances, TSCA requires a review of the health and environmental effects prior to

the manufacture of new chemical substance for commercial use.

Waste Minimization, Pollution Prevention, and Recycling Programs. The NRF waste

minimization and pollution prevention program promotes pollution prevention and waste minimization

by encouraging employees to reduce the use of hazardous materials, energy, water, and other

resources while protecting existing resources through conservation and more efficient use. The

program focuses mainly on process efficiency improvements, source reduction, inventory control,

preventive maintenance, improved housekeeping, recycling, and increasing employee awareness of

and participation in pollution prevention.

State of Idaho Water Quality Regulations. State of Idaho water quality regulations require

industrial wastewater reuse facilities to be permitted. In July 2007, the state issued NRF a permit for

use of the IWD to discharge industrial wastewater. This permit set limits and conditions in regard to

the type and amount of effluent that was discharged to the IWD. In the fall of 2020, NRF completed

the rerouting of industrial wastewater from the IWD to the non-discharging, lined, evaporative

sewage lagoons. On January 4, 2021, the IDEQ approved NRF’s Industrial Reuse Permit Closure

Plan and terminated the permit. Effluent sampling is not required at the IWD but will continue to be

done as a best management practice. NRF will continue to monitor groundwater as required in the

IDEQ approved Closure Plan.

Wildlife Collection/Banding/Possession Permit. The INL has a Wildlife Collection/

Banding/Possession Permit issued by the Idaho Department of Fish and Game. As part of the INL,

the permit is applicable to NRF. This state permit goes hand-in-hand with the federal Migratory Bird

Permit issued to the INL by the U.S. Fish and Wildlife Service. The state permit restates the

permitted actions listed in the federal permit (i.e., move or destroy problem nests, dispose of dead

animal carcasses, salvage and possess carcasses) and provides that the State of Idaho also

sanctions the actions. The state permit allows some actions beyond the scope of the federal permit;

it also allows the trapping, banding, and possession of live animals.

Other Regulations. NRF does not anticipate any substantial future impact on Site operations from

regulatory developments in other areas. However, changes in environmental regulatory

requirements are continually reviewed to ensure all NRF operations remain in compliance with

applicable laws, regulations, and standards.

NRF Environmental Summary Report

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NRF Environmental Summary Report

10.0 REFERENCES

1. Bonnichsen, B., and R. M. Breckenridge, eds. Cenozoic Geology of Idaho. Idaho Geological

Survey. Bulletin 26, 1982.

2. EG&G Idaho Inc., Geosciences Unit Staff. Naval Reactors Facility Geotechnical Investigations.

November 28, 1988.

3. Bartholomay, R. C. and Twining, B. V. 2015, Hydrologic Influences on Water-Level Changes in

the Eastern Snake River Plain Aquifer at and near the Idaho National Laboratory, Idaho, 1949-

2014: U.S. Geological Survey Scientific Investigations Report 2015-5085 (DOE/ID-22236).

4. U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response.

Application of the CERCLA Municipal Landfill Presumptive Remedy to Military Landfills.

Directive No. 9355.0-67FS, EPA/540/F-96/020, PB96-963314. December 1996.

5. Davis, L.C., Bartholomay, R.C., Rattray, G.W., 2013. An Update of Hydrologic Conditions and

Distribution of Selected Constituents in Water, Eastern Snake River Plain Aquifer and Perched

Groundwater Zones , Idaho National Laboratory, Idaho, Emphasis 2009-2011: U.S. Geological

Survey Scientific Investigations Report 2013-5214.

6. Rattray, G.W., and Wehnke, A.J., 2005. Radiochemical and Chemical Constituents in Water

from Selected Wells and Springs from the Southern Boundary of the Idaho National Laboratory

to the Hagerman Area, Idaho, 2003: U.S. Geological Survey Open-File Report 2005-1125.

NRF Environmental Summary Report

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DISTRIBUTION

Chairman

Shoshone-Bannock Tribes

Regional Administrator

Office of the Regional Administrator

US Environmental Protection Agency,

Region 10

Remedial Project Manager

US Environmental Protection Agency,

Region 10

Oregon Operations Office

Director

Idaho Department of Environmental Quality

FFA/CO Program Supervisor

Waste Management and Remediation Division

Idaho Department of Environmental Quality

State Air Quality Division Administrator

Idaho Department of Environmental Quality

INL Settlement Agreement Coordinator

INL Oversight Program

Regional Administrator

Idaho Department of Environmental Quality

INL Oversight Program Manager

Idaho Department of Environmental Quality

Manager

Idaho Operation Office

U.S. Department of Energy (3 copies)

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