Rocky Flats - DEIS


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.

1.  The DEIS does not adequately explain the DOE's choice of the Preferred Strategic Management Approach.

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 m3) 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 m3) 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 m3, of which 220,000 m3 is at LANL (p. 47).

The annual rate of production of LLW at LANL is about 6,500 m3 per year, with much variation from one year to the next.  The disposal area (Area G) has a remaining capacity of about 20,000 m3, 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.


Greg Mello
Executive Director
Los Alamos Study Group

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