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DOE OSTI2020

PORFLOW Implementation of Vadose Zone Conceptual Model for Naval Reactor Component Disposal Areas in the E-Area Low Level Waste Facility Performance Assessment

PORFLOW models have been developed to implement the proposed conceptual models for the two Naval Reactor Component Disposal Areas (NRCDAs), 643-7E and 643-26E, for the purpose of evaluating dose impacts and producing disposal limits for the E-Area Low-Level Facility (LLWF). New NRCDA conceptual models were proposed by Wohlwend and Butcher (2019) for two areas within/adjacent to the E-Area LLWF used as storage/disposal sites for reactor components from the U.S. Navy since 1987. Naval Reactor (NR) waste is comprised of highly radioactive components consisting of activated corrosion-resistant metal alloy contained within welded thick-walled steel casks, and auxiliary equipment primarily contaminated with lower levels of Activated Corrosion Products (ACPs) residing on the metal surfaces and contained within thinner-walled bolted containers.

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DOE OSTI2022

PORFLOW Implementation of Vadose Zone Conceptual Model for Naval Reactor Component Disposal Area in the E-Area Low Level Waste Facility Performance Assessment

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DOE OSTI2019

Justification for Use of the HELP Model to Estimate Infiltration Rates for the E-Area Low-Level Waste Facility Performance Assessment

Whiteside et al. conducted an in-depth literature review and performed basic infiltration model simulations to evaluate the Hydrologic Evaluation of Landfill Performance (HELP) model against five alternative computational codes utilizing the Richards equation for variably-saturated flow. Of the five alternatives considered (LEACHM, UNSAT-H, SVFlux, HYDRUS-2D3D, and VADOSE/W), only HYDRUS-2D3D and VADOSE/W were selected for further evaluation, which consisted of a side-by-side comparison versus HELP of calculated infiltration rates through a one-layer soil column with two percent slope.

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DOE OSTI2025

Reassessment of Dose Contributions from the Paducah Cask Special Waste Form Buried in the E-Area Low-Level Waste Facility

During a recent revision to the groundwater and inadvertent human intruder screening analysis report (Aleman and Hamm, 2023), weaknesses within the screening logic were observed resulting in the addition of U-235 being brought back into the list of radionuclides requiring inventory limits within the Paducah Cask special waste form (SWF). In addition, while reviewing the earlier vadose zone transport analysis efforts, an inconsistency was observed in the initial U-235P inventory that was supplied to the Consolidated Waste Tracking System (CWTS) back in 2009.

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DOE OSTI2025

Reassessment of Dose Contributions from the M-Area Glass Special Waste Form Buried in the E-Area Low-Level Waste Facility

During a recent revision to the groundwater (GW) and inadvertent human intruder (IHI) screening analysis report (Aleman and Hamm, 2023), weaknesses within the screening logic were observed resulting in U-235 being brought back into the list of radionuclides requiring inventory limits within the M-Area Glass SWF. In addition, while reviewing the earlier vadose zone (VZ) transport analysis efforts, an input deck error was observed in the U-234G VZ transport simulation.

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DOE OSTI2024

Monitoring Plan for the Idaho National Laboratory Remote Handled Low Level Waste Disposal Facility

This monitoring plan for Idaho National Laboratory’s Remote-Handled Low Level Waste Disposal Facility was developed to meet the requirements for monitoring low-level waste disposal facilities according to the U.S. Department of Energy (DOE) Order 435.1, “Radioactive Waste Management,” and the guidance provided in the associated technical standard “Disposal Authorization Statement and Tank Closure Documentation” (DOE-STD-5002-2017). The purpose of this monitoring plan is to document a monitoring strategy that includes (1) compliance monitoring activities to demonstrate compliance with regulatory standards/limits and (2) performance monitoring to build confidence the facility is performing as demonstrated in the facility performance assessment (PA) (DOE-ID 2018a), composite analysis (CA) (DOE ID 2012), and CA addendum (DOE-ID 2018b). The de minimus impact to the aquifer predicted by the PA suggests that aquifer compliance monitoring should be augmented with performance monitoring of the drainage course materials and sedimentary interbeds in the vadose zone beneath the facility to provide a more effective means of identifying performance deviations. The monitoring approach delineated in this document was informed by the systems evaluation of natural and engineered facility features presented in the PA, an assessment of aquifer baseline conditions (INL 2017d), the dose analysis conducted in support of the PA and CA, and monitoring data collected during the first four years of facility operations (baseline monitoring phase) (INL 2023b). This plan provides monitoring locations, sampling frequencies, and sampling methods; recommendations for data evaluation; and a description of the monitoring plan implementation. Collected data will be used to demonstrate facility compliance and to identify conditions that are not consistent with the key assumptions made by the PA and CA.

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DOE OSTI2019

Development of the Waste Acceptance Criteria for the Idaho National Laboratory Remote-Handled Low-Level Waste Disposal Facility - 19143

The Idaho National Laboratory (INL) Remote-Handled Low-Level Waste (RH LLW) Disposal Facility has been constructed, has received operational approval from the Department of Energy (DOE), and is expected to receive its first waste shipment in FY 2019. The RH LLW Disposal Facility will support the needs of INL and the Naval Reactors Facility (NRF). RH LLW destined for the facility includes waste currently in storage from previous programs and projects conducted at INL; newly generated waste from programs and projects conducted at INL; and waste from NRF spent fuel processing activities. This new facility supports RH LLW disposal needs for the ongoing mission of INL and NRF. Waste to be disposed of at the RH LLW Disposal Facility may exhibit dose rates that range from 0.002 Sv/hr to 600 Sv/hr. Waste types include resins and activated metals as well as surface-contaminated debris generated from existing and new missions. The total number of canisters currently planned for disposal at the RH LLW Disposal Facility is 939 with the possibility of future expansion. The projected waste volume to be disposed of is 3,100 m{sup 3}. The RH LLW Disposal Facility will receive a wide variety of RH LLW and is in preparations to receive its first canisters in FY 2019. Waste acceptance criteria (WAC) and the radioactive waste management basis have been developed and implemented in accordance with the applicable DOE Order. In order to ensure that DOE requirements and guidance were appropriately implemented in the RH LLW Disposal Facility WAC, the project worked closely with the DOE Low Level Waste Disposal Facility Federal Review Group (LFRG) representatives and followed the applicable DOE standard. This paper provides an overview of the development of the WAC, including waste and waste generator certification requirements, for the RH LLW Disposal Facility. The paper illustrates the importance of maintaining strong ties to the development and revision of the RH LLW Disposal Facility Performance Assessment (PA), Documented Safety Analysis, Facility Procedures, Readiness Reviews, DOE Order, and applicable Technical Standards. The paper also provides an overview of the RH LLW Disposal Facility, WAC generator certification requirements, distinctive challenges to acceptance of legacy waste, and the unique approach the RH LLW Disposal Facility has taken to ensure compliance with PA driven limits. (authors)

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DOE OSTI2020

Groundwater and Intruder Radionuclide Screening

Solid Waste Management (SWM) operates the E-Area Low-Level Waste Facility (ELLWF) where low level on-site and off-site solid waste streams are buried. The facility has been in operation since late 1994 and is currently projected to remain in operation until 2065. This facility can accommodate a broad range of waste forms resulting from the six different types of disposal unit options (i.e., varying degrees of engineered barriers → trenches to concrete vaults). This facility is currently operating under a Performance Assessment (PA) issued back in 2008, along with several subsequent supporting Special Analyses (SA). The Savannah River National Laboratory (SRNL) developed the prior PAs and SAs and has been tasked to update the facility’s PA. For operating the E-Area facility, a Waste Inventory Tracking System (e.g., WITS) is actively employed by waste generators where every radionuclide entering the facility (to be buried in one of its many disposal units) must be either directly or indirectly accounted for. Since there is a large number of radionuclides in existence (>3,000), the International Commission on Radiological Protection (ICRP-107) has provided guidance on the subset of radionuclides requiring further assessment in landfills such as the E-Area LLWF. The ICRP-107 publication provides critical radiological information on 1,252 radionuclides of 97 elements. This database is the critical starting point for developing a consistent inventory limit system. The explicit measurement and tracking of all radionuclides are not necessary when process knowledge, burial history, and radiological aspects are factored into conservative groundwater and intruder screening processes. Across the DOE complex these screening processes have been historically performed using the methodology suggested by the National Council on Radiation Protection and Measurements (NCRP) as presented in their original report (NCRP 1984) and then refined in a later report (NCRP 1996). In the recommended screening models employed within this report the traditional NCRP models are updated to better handle progeny and better reflect the known characteristics of E-Area. This improved screening process is referred to as the “NCRP-like” method. Various upgrades to the traditional NCRP methodology have been used by others (e.g., NRC funded effort by Kennedy and Strenge 1992). The more detailed models by Kennedy and Strenge (1992) were considered in this effort and are compared to the results from the more traditional NCRP-like models. The groundwater and inadvertent intruder screening analyses presented in this report start with this 1,252 radionuclide list and reduces it down to more manageable lists that are applicable to the various disposal unit types contained within E-Area. In order to reduce this starting list, some level of exposure risk must be considered acceptable. Historically, a dose (or concentration level) has been compared with a screening criterion set to 1% of a performance measure (e.g., a beta-gamma dose not to exceed the 4 mrem/yr beta-gamma performance measure x 0.01 = 0.04 mrem/yr). Thus, if a radionuclide produced a bounding or screening-level dose (or concentrations) less than the screening criterion, it could be safely removed from further consideration. Several tiers of screening and bounding level analyses have been considered in this report.

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DOE OSTI2020

Groundwater and Intruder Radionuclide Screening

Solid Waste Management (SWM) operates the E-Area Low-Level Waste Facility (ELLWF) where low level on-site and off-site solid waste streams are buried. The facility has been in operation since late 1994 and is currently projected to remain in operation until 2065. This facility can accommodate a broad range of waste forms resulting from the six different types of disposal unit options (i.e., varying degrees of engineered barriers → trenches to concrete vaults). This facility is currently operating under a Performance Assessment (PA) issued back in 2008, along with several subsequent supporting Special Analyses (SA). The Savannah River National Laboratory (SRNL) developed the prior PAs and SAs and has been tasked to update the facility’s PA. For operating the E-Area facility, a Waste Inventory Tracking System (e.g., WITS) is actively employed by waste generators where every radionuclide entering the facility (to be buried in one of its many disposal units1) must be either directly or indirectly accounted for. Since there is a large number of radionuclides in existence (>3,000), the International Commission on Radiological Protection (ICRP-107) has provided guidance on the subset of radionuclides requiring further assessment in landfills such as the E-Area LLWF. The ICRP-107 publication provides critical radiological information on 1,252 radionuclides of 97 elements. This database is the critical starting point for developing a consistent inventory limit system. The explicit measurement and tracking of all 1,252 ICRP-107 radionuclides can be reduced when process knowledge, burial history, and radiological aspects are factored into conservative groundwater and intruder screening processes. Across the DOE complex these screening processes have been historically performed using the methodology suggested by the National Council on Radiation Protection and Measurements (NCRP) as presented in their original report (NCRP 1984) and then refined in a later report (NCRP 1996). In the recommended screening models employed within this report the traditional NCRP models are updated to better handle progeny and better reflect the known characteristics of E-Area. This improved screening process is referred to as the “NCRP-like” method. Various upgrades to the traditional NCRP methodology have been used by others (e.g., NRC funded effort by Kennedy and Strenge 1992). The more detailed models by Kennedy and Strenge (1992) were considered in this effort and are compared to the results from the more traditional NCRP-like models. The groundwater and inadvertent intruder screening analyses presented in this report start with this 1,252 radionuclide list and reduces it down to more manageable lists that are applicable to the various disposal unit types contained within E-Area. In order to reduce this starting list, some level of exposure risk must be considered acceptable. Historically, a dose (or concentration level) has been compared with a screening criterion set to 1% of a performance measure (e.g., a betagamma dose not to exceed the 4 mrem/yr beta-gamma performance measure x 0.01 = 0.04 mrem/yr). Thus, if a radionuclide produced a bounding or screening-level dose (or concentrations) less than the screening criterion, it could be safely removed from further consideration. Several tiers of screening and bounding level analyses have been considered in this report.

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DOE OSTI2019

Natural and Engineered Features Supporting Environmental Performance of Idaho National Laboratory's Remote-Handled Low-Level Waste Disposal Facility - 19436

The Idaho National Laboratory's (INL's) Remote-Handled Low-Level Waste (RH LLW) Disposal Facility has been designed and constructed to receive waste generated at the INL site in support of the US DOE Office of Nuclear Energy (NE) and Naval Reactors (NR) missions. The facility has been designed to receive legacy RH LLW currently in storage at INL facilities and new waste generated by nuclear research programs. RH LLW to be received at the facility is solid waste consisting of surface contaminated materials; ion exchange resins used to purify cooling and canal water; and activated metal components generated during reactor core change outs and Naval spent fuel management; and nuclear R and D. Disposal of INL's RH LLW poses unique disposal challenges due to high radiation levels (contact rates up to 600 Sv/hr [60,000 Rem/hr]) that require remote handling and adequate shielding for transportation and disposal. The facility has been designed to meet the requirements of DOE Order 435.1, Radioactive Waste Management, including the all-pathways dose, air pathway dose, inadvertent intruder doses, and radon emissions limits. This paper presents an overview of natural and engineered design features that support the safety case and enhance the environmental performance of the facility. These features include location selection, use of reinforced pre-cast concrete vaults; a robust hydraulic drainage system; use of steel waste canisters for waste disposal; the facility monitoring system; facility layout; and crediting waste forms. The facility performance assessment (PA) developed to meet the requirements of DOE Order 435.1, credits each of these protective features. Releases from waste forms disposed of at this facility are limited by corrosion of the steel waste canisters which will ultimately allow contact with infiltrating water followed by transport of radionuclides from the vault system. The steel waste canisters were credited for their ability to limit water contact with the waste based on the demonstrated ability of the reinforced pre-caste concrete vaults to provide long-term structural protection of the steel waste canisters. Verification of hydraulic and concrete performance was conducted through laboratory data, field infiltration tests supported by a robust monitoring system, and numerical modeling. Releases into the vault system from activated metals are based on site-specific corrosion data. Radionuclide transport from the vault system from all waste forms is based on site-specific climatological, hydrologic, and stratigraphic data. At INL, the groundwater pathway historically and appropriately has received the most attention. By crediting aspects of the natural system, the engineered vault system, and the waste, estimated radiologic doses via the groundwater pathway are minimal. Air pathway doses were reduced by differentially crediting corrosion of aluminum and stainless steel activated metals resulting in the pathway being screened out of the PA. Groundwater and inadvertent intruder doses were reduced through selective facility layout. This paper provides an overview of the system-wide protective features incorporated into the facility design along with an extensive reference list to supporting technical papers and analyses that provide data and interpretation. (authors)

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DOE OSTI2023

Assessment of Baseline Monitoring Data for the Remote-Handled Low-Level Waste Disposal Facility at Idaho National Laboratory

The purpose of this document is to summarize environmental monitoring data collected at the Remote-Handled Low-Level Waste (RHLLW) Disposal Facility during the first four years of facility operations (FY 2019 through FY 2022). This summary provides a “baseline” condition for the facility, which can be used to distinguish contaminant releases from the RHLLW Disposal Facility from pre existing contamination as well as potential future releases from other sources (i.e., upgradient aquifer sources), as specified in the facility monitoring plan. Sufficient data has been collected over the first four years of operation of the RHLLW Disposal Facility to establish baseline conditions for future compliance monitoring of aquifer wells and performance monitoring of vadose zone lysimeters. Except for seven elevated tritium measurements from lysimeter HFEF-South believed to have been impacted by waste disposals, all data was deemed appropriate for establishing baseline concentrations. Monitoring of the aquifer detected indicator analytes gross alpha and gross beta and target analytes tritium and C-14. There were a few C-14 detections prior to an increase in the required detection level (RDL) after the first round of sampling. I-129 and Tc-99 were not detected above RDLs in aquifer samples. Lysimeter samples detected indicator analytes gross alpha and gross beta and target analyte tritium. Target analytes C-14, I-129, and Tc-99 were not detected above RDLs in lysimeter samples. Except for tritium, baseline concentrations of indicator and target analytes measured during the first four years of RHLLW facility operations are expected to represent conditions through the expected 20 year operating period of the facility. Elevated tritium in the aquifer, a result of past discharges of tritium at upgradient facilities, showed a decline over the first four years of operations, and levels are expected to continue to decline with time as a result of dilution and decay. Current tritium levels in lysimeter samples may be elevated due to tritium in the water applied during construction and infiltration testing of the facility. As a result, tritium concentrations in lysimeters may decline with time as a result of dilution and decay. Statistical measures (i.e., mean, standard deviation, and 99% upper confidence level [UCL]) were calculated for all detected analytes using the four years of concentration data. These measures will be used to evaluate future monitoring results and to demonstrate the facility is performing, or not performing, as established in the facility performance assessment (PA). Future monitoring results will also be combined with the baseline data in this report to further establish temporal trends and natural variability in the measurements. Based on the data collected during the baseline period, it is recommended the gross alpha action level for performance monitoring increase from 10 to 20 pCi/L due to several baseline measurements exceeding the preliminary action level of 10. An action level of 20 pCi/L is slightly greater than the 99% UCL, is protective of the aquifer, and would reduce unnecessary sampling. It is also recommended that tritium be added to the lysimeter analyte list for post-baseline period monitoring. Tritium, while not a dose concern, is a good tracer that can provide valuable information on water flow in and around the RHLLW Disposal Facility. Recommendations for a tritium action level are provided if considered necessary.

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DOE OSTI2025

Annual Summary Report for the Remote-Handled Low-Level Waste Disposal Facility—FY 2024

This Fiscal Year (FY) 2024 annual summary report (ASR) documents the continued adequacy of the performance assessment (PA), the composite analysis (CA), and associated operating disposal- authorization statement (ODAS) technical-basis documents for the Remote-Handled (RH) Low-Level Waste (LLW) Disposal Facility at Idaho National Laboratory (INL). Annual review of the adequacy of the PA and CA for the Remote-Handled Low-Level Waste (RHLLW) Disposal Facility ensures that conclusions of the analyses remain valid in accordance with requirements of Department of Energy (DOE) Order 435.1, “Radioactive Waste Management.” In FY 2024, no significant operational changes or other activities occurred that would cause deviation from the assumptions in the PA and CA pertaining to disposal geometry, verification of waste characteristics, tracking disposal inventories against total limits, facility-closure design, or institutional controls. Nineteen waste canister shipments were received at the RHLLW Disposal Facility, and all nineteen waste canisters were emplaced in disposal vaults.

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DOE OSTI2023

Impact to Groundwater All-Pathways Dose Estimates for the Remote-Handled Low-Level Waste Disposal Facility Performance Assessment Using Updated Dose Coefficients from DOE-STD-1196-2022

The Performance Assessment (PA) for the Remote-Handled Low-Level Waste (RHLLW) Disposal Facility at Idaho National Laboratory (INL) was completed in 2018 (DOE-ID 2018) using dose coefficients from U.S. Department of Energy (DOE) Standard DOE-STD-1196-2011 (DOE 2011). Internal and external dosimetry was updated in 2021 and a new technical standard was published in 2022 (DOE-STD-1196-2022) (DOE 2022). This technical memorandum provides a comparison of the ingestion dose coefficients between those published in DOE (2011) and those published in DOE (2022). The dose coefficients in DOE (2022) were then used to calculate the all-pathways dose for the groundwater pathway and the results between the doses published in the 2018 PA and those calculated using the updated dose coefficients in DOE (2022) were compared. Several other issues in the 2018 RHLLW Disposal Facility PA were also addressed.

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DOE OSTI2022

Annual Summary Report for the Remote-Handled Low-Level Waste Disposal Facility—FY2021

This Fiscal Year (FY) 2021 annual summary report (ASR) documents the continued adequacy of the performance assessment (PA), the composite analysis (CA) and associated operating disposal-authorization statement (ODAS) technical basis documents for the Remote Handled (RH) Low-Level Waste (LLW) Disposal Facility at Idaho National Laboratory. Annual review of the adequacy of the PA and CA for the RHLLW Disposal Facility ensures that conclusions of the analyses remain valid in accordance with requirements of Department of Energy (DOE) Order 435.1, “Radioactive Waste Management.” In FY 2021, no significant operational changes or other activities occurred that would cause deviation from the assumptions in the PA and CA pertaining to disposal geometry, verification of waste characteristics, tracking disposal inventories against total limits, facility closure design, or institutional controls. Sixteen total waste-canister shipments were received at the RHLLW Disposal Facility, and 16 total waste canisters were emplaced.

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DOE OSTI2024

Presentation on the INL Remote-Handled Low-Level Waste Disposal Facility FY-2023 Annual Summary Report

The abstract below is from the report INL/RPT-24-76103. The powerpoint presentation contains information taken from the report. This Fiscal Year (FY) 2023 annual summary report (ASR) documents the continued adequacy of the performance assessment (PA), the composite analysis (CA) and associated operating disposal-authorization statement (ODAS) technical basis documents for the Remote Handled (RH) Low-Level Waste (LLW) Disposal Facility at Idaho National Laboratory. Annual review of the adequacy of the PA and CA for the RHLLW Disposal Facility ensures that conclusions of the analyses remain valid in accordance with requirements of Department of Energy (DOE) Order 435.1, “Radioactive Waste Management.” In FY 2023, no significant operational changes or other activities occurred that would cause deviation from the assumptions in the PA and CA pertaining to disposal geometry, verification of waste characteristics, tracking disposal inventories against total limits, facility closure design, or institutional controls. Sixteen total waste-canister shipments were received at the RHLLW Disposal Facility, and 15 total waste canisters were emplaced.

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DOE OSTI2023

Annual Summary Report for the Remote-Handled Low-Level Waste Disposal Facility—FY 2022

This Fiscal Year (FY) 2022 annual summary report (ASR) documents the continued adequacy of the performance assessment (PA), the composite analysis (CA) and associated operating disposal-authorization statement (ODAS) technical-basis documents for the Remote-Handled (RH) Low-Level Waste (LLW) Disposal Facility at Idaho National Laboratory. Annual review of the adequacy of the PA and CA for the RHLLW Disposal Facility ensures that conclusions of the analyses remain valid in accordance with requirements of Department of Energy (DOE) Order 435.1, “Radioactive Waste Management.” In FY 2022, no significant operational changes or other activities occurred that would cause deviation from the assumptions in the PA and CA pertaining to disposal geometry, verification of waste characteristics, tracking disposal inventories against total limits, facility-closure design, or institutional controls. Fifteen waste canister shipments were received at the RHLLW Disposal Facility, and 15 waste canisters were emplaced in disposal vaults.

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DOE OSTI2024

Annual Summary Report for the Remote-Handled Low-Level Waste Disposal Facility—FY 2023

This Fiscal Year (FY) 2023 annual summary report (ASR) documents the continued adequacy of the performance assessment (PA), the composite analysis (CA) and associated operating disposal-authorization statement (ODAS) technical-basis documents for the Remote-Handled (RH) Low-Level Waste (LLW) Disposal Facility at Idaho National Laboratory. Annual review of the adequacy of the PA and CA for the RHLLW Disposal Facility ensures that conclusions of the analyses remain valid in accordance with requirements of Department of Energy (DOE) Order 435.1, “Radioactive Waste Management.” In FY 2023, no significant operational changes or other activities occurred that would cause deviation from the assumptions in the PA and CA pertaining to disposal geometry, verification of waste characteristics, tracking disposal inventories against total limits, facility-closure design, or institutional controls. Eleven waste canister shipments were received at the RHLLW Disposal Facility, and ten waste canisters were emplaced in disposal vaults.

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DOE OSTI2026

Annual Summary Report for the Remote-Handled Low-Level Waste Disposal Facility—FY 2025

The U.S. Department of Energy (DOE) requires the performance assessment (PA) (Department of Energy Idaho Operations Office [DOE-ID] 2018a), composite analysis (CA) (DOE-ID 2012), and CA addendum (DOE-ID 2018b) for the Remote-Handled Low-Level Waste (RHLLW) Disposal Facility at the Idaho National Laboratory (INL) Site shall be maintained to evaluate changes that could affect the performance, design, and operating basis for the facility (DOE Manual 435.1-1 Change 3, “Radioactive Waste Management Manual,” Section IV.P. [4]). The RHLLW Disposal Facility became operational in September 2018 after the completion of operational readiness activities required by DOE Order 425.1D, “Verification of Readiness to Start Up or Restart Nuclear Facilities,” and the issuance of the startup authorization by the Startup Approval Authority (Boston 2018). The first waste disposals at the RHLLW Disposal Facility began in Fiscal Year (FY) 2019. In Fiscal Year (FY) 2025, no significant operational changes or other activities occurred that would cause deviation from the assumptions in the PA and CA pertaining to disposal geometry, verification of waste characteristics, tracking disposal inventories against total limits, facility closure design, or institutional controls. This FY 2025 annual summary report (ASR) documents the continued adequacy of the PA, CA, operating disposal authorization statement (ODAS) (ODAS 2018), ODAS technical-basis documents, and the radioactive waste management basis (RWMB) (INL 2024a) to meet DOE Order 435.1, “Radioactive Waste Management,” performance objectives for the RHLLW Disposal Facility. Annual review of the adequacy of the PA and CA at the RHLLW Disposal Facility ensures that conclusions of the analyses remain valid in accordance with requirements of DOE Order 435.1.

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