INTEC Liquid Waste Management System Related Tank List

New Waste Calcine Facility, High-level Liquid Waste Evaporator, Process Equipment Waste Evaporator,

Liquid Effluent Treatment and Disposal Waste Operations

Revision # 14; 12/3/03 ICPP Tanks/ILWMS.tank.14.LST

Note # 2; The ILWMS system tanks vent to the INTEC Vessel Off-Gas System (VOG) which provides vacuum and filtration for the off-gas from the tanks in the connected facilities. The VOG system flows to the process Atmospheric Protection System (APS) filters, which are located in CPP-649 and from the APS, the off-gas is exhausted to the INTEC Main Stack in CPP-708. The APS is not a RCRA permitted system. Tank "Sparging" which is a process of forcing large amounts of air through tanks to volitize VOC's is a common practice at INTEC to reduce reporting of RCRA/CAA hazardous air pollutants. [DOE/ID letter to IDEQ 6/21/99] HWMA/RCRA Work Plan for INEEL Revised Date September 12, 2002 for EPA ID No. ID 4890008952 shows 29 tanks with the T01 "Tank Treatment" designation, that would include sparging.

Note # 3; Tank Treatment includes use of chemicals such as aluminum nitrate, sodium hydroxide, nitric acid, calcium nitrate, fluoride, boric acid, and oxalic acid to limit the potential for corrosion, prevent precipitation of solids from the waste solution, and provide for criticality control measures. It is uncertain that these hazardous chemicals are included in the RCRA waste codes.

Note # 4; Tank and secondary containment material noted as Nitronic-50, and Stainless Steel (SS). It must be noted that the pans are not capable of containing the whole volume of the tank, and therefore not compliant with RCRA for full secondary containment. Additionally, there is inadequate information about the sumps [See NOV violations 8/2/99 and DOE response NOV 055 to 063 Attachment B] having full secondary stainless steel containment with connected welds to the containment pans that drain to the sumps. Nitronic 50 is an austenitic stainless steel, as is Type 304. However, Nitronic 50 has a higher Cr & Ni content and is more corrosion resistant and stronger than say Type 316 austenitic stainless steel. Good choice for a corrosion resistant tank - depending on the corrosive, however only about eighteen of the ninety-two ILWMS tanks are Nitronic-50 or Type 304 stainless steel.. Most stainless steels don't perform very well in hot (>60C) chlorides. The evaporators normal operating temperature is 110 degrees Celsius. The evaporators operating temperatures, highly corrosive waste, plus the age of the tanks make these significant compliance issues not addressed in the RCRA Part B Application. Defense Facility Nuclear Safety Board report October 2, 2001 notes corrosion problems, "An example is the LET&D evaporator, which has a failed bottom cooler in 1 of 2 trains, a possible leak in 1 or more reboiler tubes in 1 of 2 trains, and deterioration of stainless steel off-gas components."

Note # 5; Epoxy secondary containment is a painted on surface coating that does not meet RCRA compliance, not to mention the fact that it is over forty-years old and beyond its design life even as a minimal sealant. Additionally, concrete does not meet RCRA criteria for secondary containment because of its porosity and lack of resistance to corrosives. Therefore, concrete tank vaults, sumps or building walls do not qualify as secondary containment despite DOE's claims to the contrary. Compliant secondary containment by RCRA definition must, in this case, have a stainless steel liner with capacity to hold the entire contents of the tank/vessel. CPP-603 VES SFE-106 prophylactic secondary containment of chlorosulfonated polyethylene 4.5' installed 1996 still does not rise to RCRA compliant secondary containment.

Note # 6; Design Standards; only the American Society of Mechanical Engineers (ASME) has any regulatory structural/seismic significance. Additionally, ASME has no relevance with respect to RCRA requirements (i.e. secondary containment or daily access/inspection). Also the ASME standards at the time (1950s) of instillation are not necessarily the same as those currently in place.

Note # 7; The notation that a unit is "In Part B" refers to the INEEL RCRA Part B Permit Application July 2000. All other units "Not In Part B" are not included in the Permit but remain fundamental parts of the PEWE system and illegally not fully characterized.

Note # 8; Approximately 115 tanks and vessels are connected to the INTEC Liquid Waste Management System (ILWMS) that includes the Calciner, High-level Liquid Waste Evaporator (HLLWE), Process Equipment Waste Evaporator (PEWE), Liquid Effluent Treatment and Disposal (LET&D) as primary feeder or effluent units.

• •There are 66 tanks that are feeder/effluent units to the ILWMS that are identified but not fully characterized in the Part B Application or meet RCRA standards.
• •There are 87 tanks that do not have full RCRA qualified secondary containment capable of containing the full tank volume, though ten tanks have inadequate "pans" that do not have the capacity to hold the full volume of the tank as required.
• •There are 90 tanks that have no known structural certification.
• •There is an unknown but significant number of tanks that have already exceeded their design life. This is significant given the extremely corrosive type of waste being processed

Note # 9; The service waste lines connecting all the ILWMS related tanks and vessels are not fully characterized in the RCRA Part B Permit Application even though the same secondary containment criteria that applies to tanks also applies to the waste service line piping. In some cases DOE attempts to take credit for stainless steel "troughs" in concrete beds for some pipes, this does not meet full containment for highly pressurized lines using steam as the propellent that a "trough" could not possibly contain.

Note # 10; Tank Design Standards described in INEEL RCRA Part B Permit Application July 2000 (Table D-2 pg 15) for twelve tanks as the following: "Due to the age of these tanks, no documentation exists to confirm standards. Conversation with the vendor indicates the tanks were built to API or ASME Standards." No documentation is offered to verify this vendor claim therefore the "tank design" must be legitimately listed as "unknown," which by itself is enough to disqualify the use of the tank in a RCRA permitted operation.

Note # 11; The Idaho High-Level Waste Environmental Impact Statement shows (page 5-206) that CPP-604 Waste Treatment Building (Process Equipment Waste Evaporator) tanks as a hazard based on "criticality event releasing significant radioactivity to the atmosphere." This would include VES-WL-102, and VES-WL-133, but also likely other sediment tanks related to the HLLWE and the LET&D.

Sources:

1. INEEL Interim Status RCRA Part B Workplan (GZ00-048G)

2. Hazardous Waste Management Act/Resource Conservation Recovery Act INEEL Work Plan For INEEL; EPA No. ID4890008952, 6/6/2000, and Revised Report dated September 12, 2002.

3. INEEL RCRA Interim Status Document for PEWE, Nov. 25, 1997

4. INEEL RCRA Part B Application Volume 14 Section D 7/2000

5. Facility Assessment of the New Waste Calcining Facility Evaporator Tank System (Rev. 1) November 2000

Department of Energy, INEEL/EXT-2000-1148

6. Voluntary Consent Order Information for Item # 2 for FOIA Request Dated 4/16/201 from D. McCoy, 2/15/02

7. DOE Voluntary Consent Order, Site-Tank-004: Active Hazardous Waste Tanks to be Placed on Part A/B Permit, 6/1/00

8. Idaho Department of Environmental Quality, Notice of Deficiency, April 12, 2002

9. RCRA Revision # 19 4/99, INTEC

10. Notice of Violation (NOV-055 to 063 Attachment A & B)

EDI\INEEL\ICPP Tanks\ ILWMS.tank.14.lst