December 29, 1997
Mr. Charles R. Head
U. S. Department of Energy
Office of Environmental Management, EM-60
1000 Independence Avenue, SW
Washington, D. C. 20585-0001
Re: Comments on the "Draft Environmental Impact Statement (DEIS)
on Management of Certain Plutonium Residues and Scrub Alloy Stored at
the Rocky Flats Environmental Test Site"
Dear Mr. Head:
The Los Alamos Study Group would like to offer the following comments
on the Draft Environmental Impact Statement on Management of Certain
Plutonium Residues and Scrub Alloy Stored at the Rocky Flats Environmental
Test Site (DEIS).
To summarize the points listed below, this DEIS does not provide
adequate information on which to base decisions concerning the management
of the residues and scrub alloy at Rocky Flats Environmental Test Site,
nor does it present sufficiently detailed analysis of the full range
of alternative management strategies.
Many of the analyses of the processes to be implemented are based on
pilot-scale demonstrations that may or may not work at expected production
levels. The data provided in the DEIS concerning the environmental
impacts of these processes is, then, necessarily speculative.
The EIS should be delayed until these processes have been demonstrated
and their environmental impacts measured. Only then can an informed
decision be made concerning their relative impacts.
Because the data concerning the environmental impacts are speculative,
the choice of alternative management strategies made in the DEIS
is premature. For example, the proposed processes for treating
salts at Los Alamos National Laboratory are said in this DEIS
to have high technical uncertainty. In addition, the DEIS
does not analyze the problem of storage of americium-contaminated plutonium
at LANL, nor does it accurately and adequately analyze the uncertainties
concerning future waste disposal facilities expected to be available
at LANL. Decisions concerning the choice of such management alternatives
should be delayed until such uncertainties are resolved. Exact
data would enable the analysis of management alternatives not considered
in this DEIS, e.g., an alternative that minimizes waste, or one that
minimizes resource use. Both the substantiation of the data and
the broadening of the choice of management alternatives would greatly
enhance the usefulness of this DEIS to decision-makers.
The description of the screening and evaluation process for selecting
among alternative technologies is presented on pages 2-45 and 2-46.
The Preferred Strategic Management Approach appears to violate several
of the criteria listed in the description. The Preferred Strategic
Management Approach does not implement mature technologies, does not
produce the least waste, nor is it the least expensive. According
to Table S-5 (Summary, p. 47), the Preferred alternative could produce
the most combined transuranic and low level waste of any alternative
that includes plutonium separation.
For example, the Preferred Alternative for LANL assigns the water leaching
of Direct Oxide Reduction Salts to LANL. The DEIS states
that the process has only been demonstrated on a limited scale, and
that "other capabilities" might be necessary (p. 4-108). Even
the "Pyro-oxidation of direct oxide reduction salts as a precursor to
distillation ... is unproven using the existing technologies at Rocky
Flats. Salt distillation (for all three salt categories) is unproven
at the scale proposed for the residues in this program." (p. 4-107)
Although the DEIS notes that LANL "has limited storage
capacity for plutonium-bearing metals" (p. 2-47), the Preferred Alternative
would separate 188 kg of americium-contaminated plutonium.
The DEIS notes in several places that there are serious problems
associated with storing this material, yet no statement is made concerning
its storage at LANL, instead delaying the analysis to another EIS. In
addition, the DEIS notes that implementing the process at LANL
is $14 million more expensive than the alternative implementation at
Savannah River Site (SRS). Furthermore, the DEIS admits
that the amounts of materials, utilities, and energy to be used at LANL
are "not available." (p. 4-113) In summary, the DEIS admits
1) that the preferred water leach and salt distillation technologies
have not been demonstrated at the scale to be utilized, 2) that DOE
cannot specify a storage method for the americium-contaminated plutonium,
3) that the preferred strategy is more expensive than alternatives,
and 4) that the DOE does not know the resources necessary to implement
the technologies at LANL. Without this information, the environmental
impacts cannot reasonably be determined. The DEIS fails
to specify the criteria which make the chosen technologies preferable
despite these egregious failings.
The preferred approach is a collection of processes identified as preferable
by consensus of management and technical experts. As stated, "Taken
as a group, the compilation of the preferred processing options constitutes
the Preferred Strategic Management Approach for this EIS." (Summary,
p. 30) The DEIS should describe in more detail the specific
criteria for acceptance or rejection of particular alternatives, and
they should adhere to those criteria.
Appendix C of the DEIS includes a memorandum from Dana C. Christensen
which suggests that there is a policy that requires the separation and
retention of Special Nuclear Materials (SNM) "regardless of whether
there is an identified use for such materials." (p. 2) The attachment
to the memorandum notes "SNM should always be recovered to the extent
feasible..." (p. 9). This policy is not mentioned in the text
of the DEIS as one of the criteria used to choose among the alternatives.
If this is a policy which determines the choice of technologies,
then it should be discussed in detail in the text of the DEIS. For
example, data should be presented to demonstrate that the separation
of SNM actually does "minimize the amount discarded and available for
diversion; ...minimize the environmental insult of disposal; ...minimize
the amount of waste generated, etc." as claimed in the attachment (p.
9). Some of the data presented in this DEIS suggest that
at least some of these supposed benefits may be illusory. Table
S-5, for example, indicates that the amount of waste expected to be
produced by the Preferred Alternative is similar to the amount expected
from the Process without Plutonium Separation Alternative. Also,
the separated plutonium to be produced by the Preferred Alternative
could be more easily diverted than the contaminated plutonium mixed
into waste and residues. Theses two examples indicate that the
premises of the policy concerning plutonium separation requires an examination
in this DEIS.
2. Many of the analyses of environmental impacts
are speculative.
The
DEIS discusses the environmental impacts
of technological processes which have yet to be demonstrated at the
anticipated volume of production. The predicted wastes from the
several of the processes are hypothetical estimates based on experience
with bench-scale experiments. The descriptions of specific technologies
mention that some of the technologies are not proven for the variety
and volume of residues expected from Rocky Flats Environmental Test
Site (RFETS). For example, "Among the preferred processing options,
distillation of molten salt extraction salts carries the highest technical
and economic uncertainty. ...Salt distillation (for all three
salt categories) is unproven at the scale proposed for the residues
in this program" (p. 4-107). In fiscal year 1998, $20 M is being
spent on research into processing technologies, including $2 M to continue
development of the salt distillation process. Still, the
DEIS
warns that "In the event that shielding is an unacceptable alternative,
these materials may have to be processed in another manner or stored
separately prior to final disposition." (p. 2-15)
The EIS should adhere to its own stated criteria for choice among proposed
technologies: "Only those processing technologies that are mature
enough for near-term implementation were selected for detailed evaluation."
(Summary, p. 6) Of the ten technologies considered (pp. 4-107,
4-108), only one, cementation, could be implemented in one year. The
other nine technologies would require two to four years to reach production,
assuming that the processes can be scaled up. Four of the technologies
have not been proven at the production level.
Instead of making up hypothetical analyses for unproven processes, the
EIS should admit that evaluation of the hypothetical environmental impact
of an unproven technology is not an adequate substitute for real-world
data. The EIS should be delayed until the processes have been
demonstrated and their impacts have been measured. Continuing
research on the processes is on-going independently of this EIS. As
it is now, most of the technologies could not be implemented in less
than two years after the Record of Decision (ROD). Delay of the
EIS until hard data is available concerning each process would not necessarily
delay the implementation of the processes, because the technologies
would be ready for immediate implementation upon completion of the ROD.
The advantage would be that the EIS and subsequent ROD would be
based on actual data, not hypothetical guesswork. Such data might
make it possible to analyze the management alternatives that are not
analyzed in this DEIS, e.g., an alternative that minimizes waste, or
one that minimizes resource use. Current data does not permit
the analysis of such alternatives. The choice of alternatives
selected for analysis could then be more thorough and accurate.
3. The analysis of the impacts of low level
waste (LLW) and transuranic waste (TRU) misrepresents the actual situation
at Los Alamos National Laboratory (LANL).
Table 4-88, "Los Alamos National Laboratory Cumulative
Impacts," misrepresents the waste stream expected from the plutonium
separation process at LANL. (p. 4-152) For example, the amount
of TRU waste reported in the table (15,200 m
3) in the column
"Impacts from Existing Operations" corresponds to neither of the cited
sources for the data in the footnotes to the table. The amount
of LLW reported in the same column (9,450,000 m
3) encompasses
all waste ever generated in the history of LANL, including large areas
of contaminated soil. For comparison, the DOE document "Linking
Legacies" reports that the total volume of LLW at all DOE sites is about
3,300,000 m
3, of which 220,000 m
3 is at LANL (p.
47).
The annual rate of production of LLW at LANL is about 6,500 m
3
per year, with much variation from one year to the next. The disposal
area (Area G) has a remaining capacity of about 20,000 m
3,
and is expected to be filled in 1999, about the time that the salt distillation
and water leaching processes would be underway at LANL. Therefore,
disposal of the LLW could require a new or expanded disposal site at
LANL.
4. The DEIS does not present the data
required to make an informed judgment concerning environmental impacts
at LANL.
Concerning the materials, utilities and energy associated
with the processing options at LANL, the
DEIS states, "Similar
data for Los Alamos National Laboratory are not available." (p. 4-113)
Estimations of, say, waste production, are not credible in the
absence of such basic information. The amounts of liquid waste
to be produced at LANL are not mentioned. The storage capacity
for americium-contaminated plutonium is mentioned, but analysis is put
off to another document. It is unreasonable to expect that informed
decisions can be made without such information.
Inadequate information is given concerning resource use at LANL. For
example, the preference for treating Direct Oxide Reduction Salts (DORS)
at LANL instead of RFETS is based on the limited waste water treatment
capacity at RFETS. The water leach process to be used at LANL
is assumed by DOE to generate 3.4 drums of waste per kg of residues,
but the amounts of materials, utilities, and energy to be used in the
process at LANL "are not available." (p. 4-113) According to Table
4-58, the same process, if done at RFETS, would use 8.894 million liters
of water and 14.699 million liters of acid to water leach the total
of these salts. The omission of comparable figures for LANL appears
to be an unreasonable limitation of the scope of analysis of the DEIS.
The use of such volumes of liquids at LANL warrants analysis of
the environmental impacts, including volumes of liquid waste produced
and the capability of the aging Radioactive Liquid Waste Treatment Plant
to handle such volumes safely.
The
DEIS says that "the capability for water leaching is installed
and operational at LANL on a limited scale. ...If any other capabilities
were necessary they could be available in 2 to 4 years." In other
words, DOE doesn't know if the LANL facilities are sufficient for its
assigned task under the Preferred Alternative, so any estimates of environmental
impacts of the process at expected levels of production are necessarily
speculative. These data are insufficient to analyze the potential
environmental impact of implementing the process at LANL.
5. The DEIS improperly omits analysis
of the problems associated with americium contamination of the separated
plutonium.
The storage of the americium-contaminated plutonium
that remains from the processing of the salts should be analyzed in
this EIS, rather than being analyzed separately in a future EIS.
The separation of the nuclear material is the purpose of the activities
to be authorized by this EIS, yet Section 4.21, "Impacts of the Preferred
Management Approach," does not mention the storage of this material
at LANL. As noted on page 2-15, the problems with storage of the
material could alter the choice of processing technologies. Therefore,
it is reasonable to analyze the storage problems before the choice of
a process is decided.
The
DEIS should include an estimate of the amount of americium-241
that is contained in the residues. Table D-34 (p. D-78) provides
the information necessary to calculate the amount of americium in a
portion of the salts that might be sent to LANL. The
DEIS
should contain further tables detailing the composition of the salts
and the total amount of americium contained therein.
6. The data on storage capacity at the sites
are insufficient to2cts of the increased inventory of separated plutonium
that would be the product of the processes evaluated in the DEIS.
Table 4-65 in Section 4.21 misrepresents the onsite
storage capacity at Rocky Flats, Savannah River Site (SRS), and LANL.
As stated in the footnotes to the table, the amounts listed for
Rocky Flats and LANL are the current amounts of plutonium in storage
at those facilities, not the storage capacities. The amount of
storage capacity at SRS, however, refers to a planned capacity that
has yet to be built. Furthermore, the DEIS states on page
2-15 that this facility may not be capable of storing the americium-contaminated
plutonium. The delivery of tons of plutonium to facilities that
may or may not have the capacity to store the material is reasonably
considered to be a potential environmental impact worthy of analysis.
The storage facilities at LANL are limited to the basement vaults in
TA-55 until the time that the proposed Nuclear Materials Storage Facility
is completed, if it is finally built. These existing vaults are
near capacity, and LANL documents already complain that radiation exposure
to workers in the current circumstances is higher than LANL would like.
The Preferred Management Approach assigns only the DOR Salts to LANL
for water leaching. This would separate about 180 kg of plutonium
for storage in the already-crowded basement vaults. In a personal
communication, an official at Rocky Flats states that the contractors
at Rocky Flats and LANL are encouraging the salt distillation process
to be located at LANL, as well. This would separate about another
880 kg of plutonium contaminated with over 40 kg of americium-241. This
alternative is not adequately analyzed in the DEIS. For example,
left unanswered is the problem of where LANL would store so much americium-contaminated
plutonium.
The DEIS makes no statement about where this material might be
stored at LANL. The special management requirements for the americium-contaminated
plutonium are not addressed in the Storage and Disposition of Fissile
Materials EIS (p. 4-100). The DEIS promises that the storage
problems will be addressed in the proposed Surplus Plutonium Disposition
EIS, which has just started in preparation (p. 4-106). It is unreasonable
for the DEIS to propose the separation of so much plutonium without
a clear plan for where and how to store it.
Thank you for your attention to these comments.
Sincerely,
Greg Mello
Executive Director
Los Alamos Study Group
